G.R. No. 181132 - Heirs of Maramag vs. Maramag

Petitioners are the legitimate spouse (Vicenta Pangilinan Maramag) and legitimate children of the deceased Loreto C. Maramag. Respondents are Eva Verna de Guzman Maramag (concubine and suspect in Loreto’s killing), their three illegitimate children (Odessa, Karl Brian, Trisha Angelie), Insular Life Assurance Company, Ltd. (Insular), and Great Pacific Life Assurance Corporation (Grepalife).
Loreto had two life insurance policies with Insular (Policy Nos. A001544070 for ₱1,500,000; A001693029 for ₱500,000) and three plans with Grepalife (two pension plans totaling ₱1,500,000; one memorial plan of ₱50,000).

Petitioners filed in the RTC for revocation and/or reduction of insurance proceeds, alleging (a) Eva’s designation as beneficiary void for concubinage and complicity in Loreto’s death; (b) illegitimate children’s shares inofficious and subject to legitime reduction; (c) petitioners’ legitimes unsatisfied. They sought a TRO, preliminary injunction, and ₱320,000 litigation expenses and attorney’s fees.
Insular admitted it disqualified Eva and divided proceeds among the three minors, releasing Odessa’s share. Grepalife denied all claims for misrepresentation in Loreto’s application and contended insurance proceeds are strictly governed by the Insurance Code.

RTC issued (a) September 21, 2004 Resolution granting Insular’s and Grepalife’s motion to dismiss as to the illegitimate children but allowing the case to proceed against Eva and insurers; (b) June 16, 2005 Resolution upon reconsideration dismissing the entire petition for failure to state a cause of action.
CA, in CA-G.R. CV No. 85948, dismissed petitioners’ appeal for lack of jurisdiction (January 8, 2008). Petitioners filed a Rule 45 petition before the Supreme Court.

Whether, in ruling on a motion to dismiss for failure to state a cause of action, the court may consider matters not alleged in the complaint, notably defenses raised in the answer.
Whether the RTC, in granting reconsideration of its dismissal, improperly examined and weighed unproven factual allegations from the insurers’ answers.
Whether the legitimate family of the insured is entitled to insurance proceeds designated to the concubine (or distributed to the illegitimate children) under the Insurance Code and Civil Code.