Case Digest (G.R. No. 143435-36)
Facts:
Social Security Commission and Social Security System (petitioners) sought review of the Court of Appeals decision that reversed the SSC's denial of respondent Teresa G. Favila's claim to death benefits of her husband Florante Favila, who died on February 1, 1997. Teresa alleged she was the designated primary beneficiary and surviving legal spouse; SSS had paid the minor son and later adjudicated the remaining five-year guaranteed pension to the son, and SSC denied Teresa's petition by Resolution dated June 4, 2003 and Order dated January 21, 2004.
The Court of Appeals reversed on May 24, 2005 and directed payment to Teresa; SSC/SSS filed a petition for review on certiorari before the Supreme Court (G.R. No. 170195).
Issues:
- Is Teresa G. Favila a primary beneficiary under the Social Security Law and therefore entitled to death benefits from the death of Florante Favila?
- Were the investigations conducted by SSS in adjudicating the claim a violation of the right to privacy?
Ruling:
The Supreme Court granted the petition, reversed and set aside the CA Decision and Resolution, and declared Teresa not a dependent spouse within the contemplation of Republic Act No. 1161 and therefore not entitled to Florante's death benefits.
The Court also held that the investigations conducted by SSS were proper and did not violate the right to privacy, being authorized and necessary for administration of the social security system.
Ratio:
The Court applied the plain text of Sections 8(e) and 8(k) of RA 1161, which require that a qualifying spouse be both legitimate and dependent for support; under the verba legis rule the statute must be given literal effect. Precedent requires the claimant to prove dependency at the time of contingency. Teresa failed to present substantial evidence of dependency at Florante's death; the SSS evidence of long de facto separation and uncorroborated allegations of an illicit relationship did not establish that she remained dependent. Finally, the Court found SSS investigations lawful under RA 8282, Section 4(b)(7), and Section 15 of the SS Law as necessary to determine rightful beneficiaries.
Doctrine:
- A surviving spouse qualifies as a primary beneficiary only if he or she is both the legitimate spouse and *dependent for support* as defined in RA 1161, Secs. 8(e) and 8(k).
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