G.R. No. 202242 - Chavez vs. Judicial and Bar Council

Social Security Commission (SSC) filed a petition for review on certiorari assailing the Court of Appeals’ decision and resolution that had granted Edna A. Azote’s claim to death benefits for her late husband, Edgardo Azote, a member of the Social Security System (SSS).
The case centers on conflicting beneficiary designations submitted by the deceased member and the question of the legal validity of his marriage to Edna.

On June 19, 1992, Edna married Edgardo in civil rites at the Regional Trial Court, Legazpi City, Albay.
Their marriage produced six children between 1985 and 1999.

On November 5, 1982, Edgardo submitted a Form E-4 to the SSS designating Rosemarie Azote as his spouse and Elmer Azote as a dependent.
On April 27, 1994, he subsequently submitted another Form E-4, this time designating Edna and their three older children as beneficiaries. Later, on September 7, 2001, he further designated his three younger children as beneficiaries.

Edgardo died on January 13, 2005.
Edna filed a claim for death benefits as the wife of the deceased-member.
The SSS records revealed conflicting information because of the earlier Form E-4 (1982) naming Rosemarie as spouse, leading to Edna’s claim being denied.
Despite Edna’s petition with supporting evidence (e.g., her marriage certificate and the baptismal certificates of their children), the SSC maintained that Rosemarie remained the presumed legal wife since there was no evidence of annulment or dissolution of Edgardo’s prior marriage.

On December 8, 2010, the SSC dismissed Edna’s petition for lack of merit, basing its resolution on Section 24(c) of the SS Law and NSO records proving Edgardo’s prior marriage to Rosemarie.
Edna filed a motion for reconsideration, which was denied on June 8, 2011.
The Court of Appeals later reversed the SSC’s denial in its August 13, 2013 Decision, holding that Edna had established her right to the benefits with substantial evidence, and that the 1994 Form E-4 superseded the earlier designation.
The CA also ruled that since there was no contest from Rosemarie or other claimants, Edna’s designation as wife-beneficiary remained valid.

The SSC argued that the CA exceeded its authority by determining the validity of Edna’s marital status, which, in effect, involved adjudicating the legal status of the marriage.
It contended that under the SS Law and the Family Code, only a legal spouse – one not impeded by a prior valid marriage – qualifies to receive the death benefits.

Defines the social security benefits and the qualifications of dependents and beneficiaries.
Explicitly provides, through Sections 8(e) and (k), that only the legal spouse is entitled to serve as the beneficiary.

Article 41 of the Family Code invalidates a subsequent marriage if the earlier marriage subsists unless certain conditions (such as absence and presumptive death) are met.

The SSC relied on previous cases and its quasi-judicial mandate under Section 4(b)(7) of R.A. No. 8282 to validate its investigation and determination regarding beneficiary eligibility.
The investigation was based on the existence of two conflicting Form E-4 submissions and relevant documentary/statistical evidence.

Whether the SSC has the authority to determine the validity or invalidity of a claimant’s marriage for the purpose of adjudicating social security benefits.
Whether a quasi-judicial agency may rule on matters that traditionally require a determination of marital validity.

Whether Edgardo’s later Form E-4 (1994), designating Edna as his wife, effectively revoked the earlier 1982 designation naming Rosemarie.
The legal effect of conflicting beneficiary designations on the determination of the rightful claimant to SS benefits.

Whether Edna established her claim as the legal spouse by producing her marriage certificate and the baptismal certificates of her children.
Whether the non-appearance and default of Rosemarie (the designated beneficiary in 1982) should be considered a waiver of her right to claim benefits.

Whether Edna satisfied the statutory requirement under R.A. No. 8282 and the Family Code that only a legitimate or legal spouse may be entitled to the benefits.
Whether the existence of NSO records proving Edgardo’s prior marriage invalidates Edna’s claim.