Case Digest (G.R. No. 209741)
Case Digest (G.R. No. 209741)
Facts:
Social Security Commission v. Edna A. Azote, G.R. No. 209741, April 15, 2015, Supreme Court Second Division, Mendoza, J., writing for the Court.Petitioner is the Social Security Commission (SSC); respondent is Edna A. Azote, who claimed Social Security death benefits as the wife of deceased SSS member Edgardo Azote. Edgardo and Edna were married in civil rites on June 19, 1992 in Legazpi City and had six children born between 1985 and 1999. Edgardo completed multiple SSS Form E‑4 beneficiary designations: one on November 5, 1982 naming Rosemarie as wife‑beneficiary and Elmer as dependent; a later Form E‑4 dated April 27, 1994 named Edna and three older children; and another (or update) on September 7, 2001 designating three younger children.
Edgardo died on January 13, 2005. Edna filed a claim for death benefits with the SSS but the SSS records showing the 1982 Form E‑4 naming Rosemarie as wife led to denial of Edna’s claim; her children were recognized as beneficiaries with Edna as guardian for minors. On March 13, 2007 Edna filed a petition with the SSC to adjudicate entitlement to lump sum and monthly pension. The SSC published summons to Rosemarie, who did not answer and was declared in default.
In a Resolution dated December 8, 2010 the SSC dismissed Edna’s petition, relying on Section 24(c) of R.A. No. 8282 and NSO certification of Edgardo’s 1982 marriage to Rosemarie, concluding the 1992 marriage to Edna was invalid absent annulment or dissolution of the prior marriage. The SSC denied reconsideration on June 8, 2011. The Court of Appeals reversed in an August 13, 2013 Decision (CA‑G.R. SP No. 122933), holding the SSC could not determine the validity of the marriage in the absence of a contest and that the 1994 Form E‑4 manifested Edgardo’s revocation of the 1982 designation; the CA denied the SSC’s motion for reconsideration in an October 29, 2013 Resolution. The SSC filed a petition for review on certiorari under Rule 45 to the Supreme Court contesting the CA rulings.
Issues:
- Does the Social Security Commission have authority to examine available records and determine the validity of a spouse‑beneficiary designation for purposes of adjudicating SSS death benefits?
- Was Edna A. Azote entitled to be recognized as the legal spouse and primary beneficiary of deceased member Edgardo Azote under R.A. No. 8282, given the earlier 1982 Form E‑4 and NSO marriage record?
- Did the 1994 Form E‑4 designating Edna as wife‑beneficiary supersede the 1982 Form E‑4 so as to render Edna eligible for the death benefits?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)