G.R. No. 250613 - Macalinao vs. Macalinao

Pedrito G. Macalinao (Pedrito) married Cerena Negapatan Macalinao (Cerena) in 1981 and had one child, Cindy.
Pedrito and Cerena separated in fact in 1985; no court declaration of nullity or legal separation was made.
In 1990, while still married to Cerena, Pedrito entered into a marriage with Elenita V. Macalinao (Elenita) and had two children, Kenneth and Kristel.
Elenita’s marriage was bigamous and void ab initio due to the existence of the first valid marriage to Cerena.
Cerena later contracted a bigamous marriage to Rene Paredes in 1992.

Pedrito was a seafarer employed by Excel Marine Co. Ltd./Fair Shipping Corporation and a member of AMOSUP.
Pedrito died onboard his vessel in 2015, during his employment term.
Death benefits were computed at USD 93,057.88 (PHP 4,506,309.52) pursuant to POEA rules and Collective Bargaining Agreement.

In 2016, Cerena and Cindy filed a petition for nullity of Pedrito and Elenita’s marriage; later amended to the settlement of Pedrito’s estate.
Excel Marine deposited the death benefits equivalent in Philippine pesos with the RTC.
The RTC declared Elenita and Pedrito’s marriage null and void due to bigamy, declared Kenneth and Kristel illegitimate children, and ruled that death benefits formed part of Pedrito’s estate.
The RTC apportioned the death benefits: half to Cerena as legitimate spouse and the rest among Cerena and all children.
Petitioners appealed to the Court of Appeals who affirmed the RTC decision.
Petitioners filed a Petition for Review before the Supreme Court contesting among others the inclusion of death benefits as part of the estate and Cerena’s right to share them.

Whether the death benefits form part of Pedrito’s hereditary estate.
Who among the parties—Cerena (legal spouse), Elenita (bigamous spouse), and Pedrito’s children—are qualified beneficiaries of the death benefits.
How the death benefits should be fairly distributed among qualified beneficiaries.