Title
IN RE: Manlavi
Case
A.M. No. 10019-Ret
Decision Date
Feb 22, 2001
A mother forfeited her entitlement to Survivor's Benefits due to her abandonment of the family and involvement in a murder case, favoring her legitimate daughter's claim to the inheritance.
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Case Digest (A.M. No. 10019-Ret)

Facts:

  • Ms. Maylenne G. Manlavi applied for Survivor's Benefits as the legitimate daughter of the late Ernesto R. Manlavi.
  • Ernesto served as Clerk of Court II at the Municipal Circuit Trial Court in El Nido, Palawan, for 17 years, 10 months, and 13 days before his death on June 23, 1999.
  • At the time of his passing, he had one legitimate daughter, Maylenne, born on October 30, 1977, and six illegitimate children with his common-law wife, Maribelle Endocado.
  • Ernesto's legal wife, Marilou G. Manlavi, abandoned him and Maylenne in 1982 and became a fugitive due to her involvement in a murder case.
  • The community accepted Ernesto's relationship with Maribelle, and Maylenne described their union as "happy, albeit illicit."
  • The Supreme Court initially approved Maylenne's application for Survivor's Benefits on November 16, 1999, with a note on Marilou's absence.
  • Marilou resurfaced and filed her own application for benefits on January 3, 2000, which Maylenne opposed, citing abandonment and criminal issues.
  • The Court Administrator recommended denying Marilou's claim and forfeiting her shares in favor of Maylenne and her half-siblings.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that Marilou G. Manlavi is not entitled to Survivor's Benefits.
  • The Court approved the forfeiture of Marilou's shares in the Survivor's Benefits, directi...(Unlock)

Ratio:

  • The Court's decision was based on Republic Act No. 8291, which defines eligibility for Survivor's Benefits.
  • The law requires dependents, including a legitimate spouse, to be reliant on the deceased for support.
  • Marilou had abandoned her family for...continue reading

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