G.R. No. 174730-37 - Galeos vs. People

Teresa G. Favila filed a petition with the Social Security Commission (SSC) on August 5, 2002 (SSC Case No. 8-15348-02) to claim death benefits following the death of her husband, Florante Favila, who died on February 1, 1997.
In her petition, Teresa asserted that Florante had designated her as the sole beneficiary on the E-l Form submitted in June 1970 and that she had been the recipient of his benefits at various stages, including during the period when their only minor child, Florante II, was also a beneficiary.

Although Teresa contended her entitlement as the legal surviving spouse, the Social Security System (SSS) initially settled Florante’s pension benefits in favor of their minor child, Florante II, until his emancipation at age 21.
Teresa’s claim for additional death benefits was denied by the SSS in a letter dated January 31, 2002.
The claim was later re-adjudicated on July 11, 2002, and the balance of the five-year guaranteed pension benefit was again settled solely for Florante II.

A letter from Florante’s sister, Estelita Ramos, alleging that Teresa’s alleged adulterous conduct had contributed to the couple’s separation after only ten years of marriage.
Interviews in Teresa’s neighborhood in Tondo, Manila revealing that while Teresa did not cohabit with another man after her separation, there were persistent rumors of an affair with a police officer.

Teresa did not deny the existence of an adulterous relationship despite asserting that she had not remarried or cohabited with any other man.
The SSC used the evidence obtained to conclude that Teresa was not dependent on Florante for support at the time of his death.

Based on its findings, the SSC issued a Resolution on June 4, 2003, holding that entitlement to death benefits rests on two essential elements: the claimant must be both the legal spouse and dependent on the deceased for support.
The SSC found that Teresa, notwithstanding her legal status as spouse, was disqualified for benefits due to her marital infidelity and longstanding separation from Florante, as well as her failure to timely contest the non-entitlement ruling.
Teresa’s Motion for Reconsideration was denied by SSC on January 21, 2004, after which she sought further relief by elevating her case to the Court of Appeals (CA) through a Petition for Review.

Teresa argued that as Florante’s undisputed legal spouse and designated beneficiary, she was entitled to the death benefits under the Social Security Law.
The SSC maintained that under Sections 8(k) and 13 of Republic Act (RA) No. 1161, a surviving spouse must be shown to be dependent for support, a condition not met by Teresa due to the evidence of her de facto separation and alleged adulterous behavior.
The Office of the Solicitor General (OSG) supported the SSC’s contention, emphasizing that the statutory requirement of dependency had not been satisfied and noting that the benefits had already been fully disbursed to Florante II.

Whether Teresa qualifies as a primary beneficiary entitled to death benefits under the Social Security Law by virtue of being Florante’s legal surviving spouse and meeting the dependency requirement.

Whether the legal definition of “dependent spouse” under RA 1161, which requires both legitimacy and economic dependency for support, excludes a spouse who has been separated for an extended period and is alleged to have engaged in an illicit relationship.
Whether the investigation conducted by SSS and SSC—despite relying partly on uncorroborated rumors—is sufficient to deny Teresa’s claim in light of the statutory provisions.
Whether the designation of a spouse as beneficiary by the deceased member furnishes an irrebuttable presumption of dependency, absent contrary evidence, or whether the statutory parameters clearly require proof of dependency at the time of the member’s death.