Case Digest (G.R. No. 165546)
Facts:
Social Security System v. Rosanna H. Aguas, et al., G.R. No. 165546, February 27, 2006, First Division, Callejo, Sr., J., writing for the Court.Pablo Aguas, an SSS member and pensioner, died on December 8, 1996. His widow, Rosanna H. Aguas, filed for death benefits on December 13, 1996 and indicated a minor child, Jeylnn H. Aguas (born October 29, 1991). The SSS settled the monthly pension on February 13, 1997.
On April 2, 1997 Pablo’s sister, Leticia Aguas‑Macapinlac, sent a sworn letter to the SSS alleging Rosanna had abandoned Pablo years earlier, was cohabiting with another man (Romeo dela Pena), and that Rosanna’s children (including Jeylnn) were fathered by Romeo. She included a photocopy of a birth certificate for one Jefren H. dela Pena (born November 15, 1996) showing Rosanna and Romeo as parents and married November 1, 1990. The SSS suspended pension payments in September 1997, investigated the allegations, and on the basis of witness interviews and an alleged medical confirmation of Pablo’s infertility denied further payments and demanded restitution of P10,350.00.
Rosanna (and minor Jeylnn, represented by Rosanna) sought reconsideration with the SSS, which denied relief in February 1998. They then filed for restoration/payment of pensions with the Social Security Commission (SSC) on February 20, 1998 (SSC Case No. 3‑14769‑98), joined by Janet H. Aguas, who claimed to be another child of Pablo and Rosanna. Claimants submitted photocopies of marriage and birth certificates and Pablo’s death certificate; the SSS relied on the contested affidavits and documentary evidence against the claimants.
The SSC ordered verification from the civil registries and directed the SSS to verify the authenticity of Pablo’s signature on Jeylnn’s birth certificate; the SSS’s laboratory analysis matched the signature to Pablo’s specimen signatures. Hearings were held: neighbors Vivencia Turla and Carmelita Yangu testified for the claimants that the spouses lived as husband and wife until Pablo’s death; other witnesses (including Leticia and Mariquita Dizon) testified that Rosanna had been driven away after a commotion over the child’s paternity, that Rosanna lived with Romeo dela Pena, and that there were baptismal certificates indicating both a “Jeylnn Aguas” (born Oct. 29, 1991) and a “Jenelyn H. dela Pena” (born Jan. 29, 1992), suggesting contrived records and that the two names referred to the same child.
On March 14, 2001 the SSC denied the claimants’ petition for lack of merit and ordered repayment of P10,350.00, concluding Rosanna had contracted marriage with Romeo during her marriage to Pablo (constituting adultery/abandonment) and that Jeylnn was not Pablo’s legitimate child despite a signature on a birth certificate; Janet was held to be merely taken in by the spouses without legal adoption. The SSC denied the motion for reconsideration as untimely.
The claimants elevated the case to the Court of Appeals (CA) via a petition under Rule 43; on September 9, 2003 the CA reversed and set aside the SSC’s decision, declared the petitioners entitled to SSS benefits, and remanded to SSS for computation. The CA placed weight on t...(Subscriber-Only)
Issues:
- Under a Rule 45 petition, may this Court review factual findings of the Court of Appeals?
- Is Jeylnn H. Aguas entitled to SSS death benefits as a legitimate child of Pablo?
- Is Janet H. Aguas entitled to SSS death benefits as a dependent child of Pablo?
- Is Rosanna H. Aguas entitled to SSS death benefits as a depen...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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