Case Digest (G.R. No. L-44059)
Facts:
In The Insular Life Assurance Company, Ltd. vs. Carponia T. Ebrado and Pascuala Vda. de Ebrado (G.R. No. L-44059, October 28, 1977), Buenaventura Cristor Ebrado procured on September 1, 1968 a whole-life insurance policy No. 009929 for ₱5,882.00 with an equal accidental death benefit from The Insular Life Assurance Company, Ltd. He named Carponia T. Ebrado, whom he called his wife but to whom he was never legally married, as revocable beneficiary. On October 21, 1969, Ebrado died in an accident. Carponia filed a claim for the ₱11,745.73 proceeds, while Pascuala Vda. de Ebrado, his lawful wife and mother of six legitimate children, likewise claimed entitlement. The insurer, uncertain which claimant prevailed, instituted an interpleader action on April 29, 1970 in the Court of First Instance of Rizal. At the July 8, 1972 pre-trial, the parties stipulated that Ebrado was validly married to Pascuala yet concurren...Case Digest (G.R. No. L-44059)
Facts:
- Policy and Beneficiary
- September 1, 1968: Buenaventura Cristor Ebrado obtained Policy No. 009929 (whole-life plan, ₱5,882.00 face value plus identical accidental death rider).
- He designated Carponia T. Ebrado—whom he referred to as his “wife” and with whom he cohabited without marriage—as revocable beneficiary.
- Death of Insured and Amount Due
- October 21, 1969: Ebrado died in an accident (falling tree branch).
- Insular Life Assurance Co. became liable for ₱11,745.73 (face value ₱5,882.00 + accidental benefit ₱5,882.00 + premium refund ₱18.00 – unpaid premiums and interest ₱36.27).
- Competing Claims
- Carponia filed claim as designated beneficiary, admitting her status as common-law wife and mother of two of his children.
- Pascuala Vda. de Ebrado, the legal wife (mother of six legitimate children), also filed claim as widow.
- Interpleader and Stipulations
- April 29, 1970: Insurer filed an interpleader action in the Court of First Instance of Rizal to determine the rightful payee.
- July 8, 1972: In a pre-trial conference the parties stipulated nine factual points, including:
- Valid marriage of insured to Pascuala (six children).
- Existence and terms of Policy No. 009929.
- Insured’s concubinage with Carponia (two children).
- Date and cause of death.
- Both Carponia and Pascuala filed claims.
- Amount due under the policy.
- Carponia’s designation as revocable beneficiary was never changed.
- Agreed that decision be based solely on these stipulations.
- Trial Court Judgment and Appeal
- September 25, 1972: The trial court disqualified Carponia under Civil Code Art. 739 and directed payment of proceeds to the estate of the deceased.
- Carponia appealed; on July 11, 1976, the Court of Appeals certified the case to the Supreme Court as involving only questions of law.
Issues:
- Can a common-law wife designated as beneficiary in a life insurance policy claim the proceeds?
- Should the insurance proceeds be paid to the common-law wife/beneficiary or to the legal wife’s estate?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)