Case Digest (G.R. No. L-26170)
Facts:
Government Service Insurance System v. Susana, Romualdo, Julian, Macario A., Moises, Macario C., Adriano, Celestina and Luisa Custodio, G.R. No. L-26170, January 27, 1969, Supreme Court En Banc, Reyes, J., writing for the Court.The Government Service Insurance System (GSIS), plaintiff, filed an interpleader complaint on June 10, 1958 in the Court of First Instance of Rizal (Civil Case No. 5037) seeking determination of who was entitled to P8,339.36 in retirement benefits due a deceased member, Simeon Custodio. The defendants were Simeon's surviving sister, Susana Custodio (defendant–cross-claimant–appellee), and several nephews and nieces — Romualdo, Julian, Macario A., Moises, Macario C., Adriano, Celestina, Luisa and David Custodio (defendants–cross-claimants–appellants) — who claimed by right of representation as children of Simeon’s deceased brothers.
At pre-trial the parties submitted a stipulation of facts. The stipulation recited that Simeon died intestate on February 16, 1957; that an unsigned, undated retirement application naming Susana as beneficiary was found among his papers but was never filed with GSIS; that on July 7, 1957 several of the heirs (including Romualdo, Julian, Macario A., Moises, Adriano and Celestina, but excluding Macario C., Luisa and David) executed an “Extrajudicial Settlement of Estate Among Heirs” (Annex B) recognizing Susana as sole beneficiary of GSIS proceeds; and that on July 8, 1957 most of those signatories wrote GSIS repudiating that settlement (Annex C). The stipulation also showed that Macario C. is the sole child of Crispin (one of Simeon’s brothers) and that Luisa and David are two of six children of Jacinto (another brother).
The trial court, after approving the stipulation on January 2, 1960 and receiving memoranda, rendered judgment on March 10, 1960 holding that the unsigned application naming Susana was invalid but that Susana nonetheless was entitled to the retirement benefits to the exclusion of the nephews and nieces because the extrajudicial settlement (Annex B) recognized her as sole beneficiary and is presumed regular in the absence of proof of fraud or mistake. The appellants moved for reconsideration (opposition dated April 20, 1960) which was denied.
The nephews and nieces appealed to the Court of Appeals. The Court of Appeals concluded that only questions of law were involved and certified the case to the Supreme Court (i.e., certification on the ground that there were no qu...(Subscriber-Only)
Issues:
- Were the appellants’ allegations of fraud or mistake affecting the extrajudicial settlement properly before the court where such allegations were not specifically pleaded and were not included in the stipulation of facts?
- Are the non-signatory heirs (Macario C., Luisa and David Custodio) bound by the extrajudicial settlement that recognized Susana as sole beneficiary?
- If not bound, what shares of the retirement benefits d...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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