Facts:
Social Security Commission (SSC), petitioner, assailed the Court of Appeals' August 13, 2013 Decision and October 29, 2013 Resolution allowing
Edna A. Azote, respondent, to claim the death benefits of her late husband,
Edgardo Azote. On June 19, 1992, Edna and Edgardo were married in civil rites at the Regional Trial Court, Branch 9, Legazpi City, Albay, and their union bore six children born between 1985 and 1999. The deceased-member filed a Form E-4 on November 5, 1982 that designated
Rosemarie Azote as his spouse-beneficiary and
Elmer Azote as dependent; he later submitted a Form E-4 on April 27, 1994 designating Edna and their three older children as beneficiaries and a September 7, 2001 form adding the three younger children. Edgardo died on January 13, 2005. Edna filed a claim for death benefits with the SSS, but the claim was denied after SSS records showed the 1982 E-4 and an NSO marriage registration of Edgardo to Rosemarie on July 28, 1982. Edna petitioned the SSC on March 13, 2007 to claim the lump sum and monthly pension; the SSC dismissed the petition for lack of merit in a Resolution dated December 8, 2010 and denied reconsideration on June 8, 2011, reasoning that the subsistence of the prior marriage barred the validity of Edna’s marriage. The Court of Appeals reversed in its August 13, 2013 Decision, finding Edna to be the sole claimant and that the 1994 E-4 superseded the 1982 form; the CA denied SSC’s motion for reconsideration in its October 29, 2013 Resolution. The SSC filed the present petition for review on certiorari under Rule 45, which the Supreme Court resolved on April 15, 2015.
Issues:
Did the SSC act within its authority in determining the validity of the marriage of
Edna A. Azote to deceased member
Edgardo Azote for purposes of adjudicating entitlement to SSS death benefits? Was
Edna A. Azote entitled to the death benefits of
Edgardo Azote under
R.A. No. 8282, given the existence of a prior marriage of the deceased? Was the 1994 Form E-4 naming Edna as wife-beneficiary sufficient to supersede the 1982 Form E-4 and establish her status as the legal spouse for purposes of SSS benefits?
Ruling:
Ratio:
Doctrine: