Case Digest (G.R. No. 250613)
Facts:
Elenita v. Macalinao, G.R. No. 250613, April 03, 2024, Supreme Court Third Division, Caguioa, J., writing for the Court. Petitioners are Elenita V. Macalinao, and her children Kenneth V. Macalinao and Kristel V. Macalinao; respondents are Cerena (a.k.a. Cerena N.) Macalinao and Cindy N. Macalinao. The petition is a Rule 45 Petition for Review on Certiorari assailing the Court of Appeals Decision dated August 29, 2019 and Resolution dated November 25, 2019 in CA‑G.R. CV No. 112739.The controversy arises from the death on June 26, 2015 of seafarer Pedrito G. Macalinao (Pedrito), an employee of Excel Marine Co. Ltd./Fair Shipping Corp. and member of AMOSUP, whose contractual death benefits totaled USD 93,057.88 (PHP 4,506,309.52). Pedrito married Cerena on June 5, 1981 (one child, Cindy); they separated in fact. On April 3, 1990, Pedrito married Elenita while the first marriage subsisted; Pedrito and Elenita had two children, Kenneth and Kristel. Excel Marine deposited the PHP 4,506,309.52 with the RTC clerk as full settlement of its obligation.
Respondents Cerena and Cindy filed initially for declaration of nullity of Pedrito’s marriage to Elenita, which the RTC converted into an amended Petition for Settlement of Estate after clarifying the true intent. In pretrial the parties stipulated to several material facts (including the bigamous character of the second marriage and that the death benefits were the only property). Branch 207, RTC, Muntinlupa City, issued a Decision dated September 12, 2018 declaring the marriage between Pedrito and Elenita null and void for bigamy, holding the death benefits formed part of Pedrito’s estate, declaring Kenneth and Kristel illegitimate, and directing distribution of the deposited funds under Articles 888 and 892 of the New Civil Code.
Petitioners appealed to the Court of Appeals, ...(Subscriber-Only)
Issues:
- Do the proceeds of the POEA contractual death benefits form part of the decedent’s hereditary estate?
- Who are the qualified beneficiaries of those death benefits and how should the proceeds be apportioned...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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