Title
Supreme Court
Social Security System vs. Aguas
Case
G.R. No. 165546
Decision Date
Feb 27, 2006
SSS pension claim contested; Rosanna denied benefits due to separation, Jeylnn granted as Pablo's legitimate child; Janet excluded as unproven adopted child.

Case Digest (G.R. No. 165546)
Expanded Legal Reasoning Model

Facts:

  • Background and Parties
    • Pablo Aguas, a member of the Social Security System (SSS) and a pensioner, died on December 8, 1996.
    • Rosanna H. Aguas, his surviving spouse, filed a claim for death benefits on December 13, 1996, stating that Pablo was also survived by their minor child, Jeylnn, born on October 29, 1991.
    • Later, Janet H. Aguas joined the claim, alleging to be another child of Pablo and Rosanna.
  • Initiation of Dispute
    • In April 1997, the SSS received a sworn letter from Leticia Aguas-Macapinlac, Pablo’s sister, contesting Rosanna’s claim.
    • Leticia alleged that Rosanna had abandoned the family abode more than six years prior and had been living with another man, Romeo dela PeAa, asserting that Pablo had no legal children with Rosanna.
    • Supporting her allegations, Leticia submitted a notarized copy of the original birth certificate of Jefren H. dela PeAa, indicating that he was born to Rosanna and Romeo dela PeAa.
  • SSS Investigation and Initial Action
    • Based on Leticia’s allegation and an investigation conducted by a Social Security Officer (interviewing Pablo’s relatives and neighbors), the SSS suspended the payment of monthly pensions in September 1997.
    • A Memorandum of November 18, 1997, reported that:
      • Pablo had no legal children with Rosanna, but that Jenelyn and Jefren were born of Rosanna’s relationship with Romeo dela PeAa.
      • Pablo was under treatment and allegedly infertile.
    • Consequently, the SSS denied Rosanna’s request to resume payment of benefits, instructing her to refund the amount released from December 1996 to August 1997.
  • Filing before the Social Security Commission (SSC)
    • In February 1998, Rosanna, along with Jeylnn, filed a claim/petition for the Restoration/Payment of Pensions with the SSC, later joined by Janet.
    • The petition was supported by photocopies of Pablo and Rosanna’s marriage certificate, certificates of live birth for Janet and Jeylnn, and Pablo’s death certificate.
    • In its Answer, the SSS contended that, based on the testimonies and documentary evidence, the petitioners were unqualified as primary beneficiaries.
  • Testimonies and Documentary Evidence
    • Claimants' Evidence:
      • Neighbors Vivencia Turla and Carmelita Yangu submitted a Joint Affidavit asserting that Pablo and Rosanna lived together as husband and wife until Pablo’s death.
      • Janet’s birth certificate, registered in the Civil Registry of San Fernando, identified Pablo as her father.
      • The claimants argued that the alleged infertility of Pablo was unproven and that the doctor's testimony was improperly obtained.
    • SSS and SSC’s Verification:
      • Confirmation Reports from civil registers verified the facts of the marriage, the births of Jefren, Jeylnn, and the death of Pablo.
      • Laboratory analysis authenticated Pablo’s signature on Jeylnn’s birth certificate, aligning it with his SSS Form E-1 and other documents.
    • Conflicting Testimonies:
      • Vivencia and Carmelita testified to the marital unity of Pablo and Rosanna, with Vivencia asserting that Janet was merely an adopted child, and Carmelita uncertain of Jefren’s paternity.
      • Leticia maintained that Janet was not Pablo’s child and recounted that a commotion at the ancestral house led to Pablo driving Rosanna away after Romeo dela PeAa contested the baptism practices.
    • Additional Evidence:
      • Two baptismal certificates (for Jeylnn and Jenelyn) suggested that Jeylnn and Jenelyn might be the same person, creating a timeline that made successive births physically implausible.
      • Multiple affidavits and testimonies revealed that Rosanna and Pablo had been separated prior to his death, with Rosanna living with Romeo dela PeAa.
  • Decisions of the SSC and Court of Appeals
    • The SSC, on March 14, 2001, rendered a decision denying the claim, ruling that:
      • Rosanna had contracted a relationship and entered into a void marriage with Romeo dela PeAa while still married to Pablo.
      • Jeylnn was deduced to be the same person as Jenelyn (child of Rosanna and Romeo), and Janet was merely an adopted child without legal adoption papers.
    • Subsequent Motions:
      • Claimants filed a motion for reconsideration with the SSC, which was denied.
      • They elevated the case to the Court of Appeals (CA) under Rule 43 of the Rules of Court.
    • The CA Decision (September 9, 2003):
      • The CA reversed the SSC decision, declaring that, based on the verified entries in the birth certificates and the lack of evidence to support Rosanna’s separation as an indication of non-dependency, the claimants were entitled to the benefits.
      • The CA, however, recognized only the legitimacy of Jeylnn, stating that public documents (birth certificates) are binding and decisive for establishing paternity and legitimacy.
  • Petition for Review
    • The SSS, as petitioner, elevated the case to the Supreme Court via a petition for review on certiorari, alleging grave errors in the CA’s findings regarding:
      • The dependency status of Rosanna as a primary beneficiary under Section 8(e) and Section 8(k) of the SSS Law.
      • The entitlement of Janet and Jeylnn to the pension benefits.
    • The petition recited relevant provisions from Republic Act No. 1161, as amended by Presidential Decree No. 735, emphasizing the definition of a dependent spouse and primary beneficiaries.

Issues:

  • Whether Rosanna, Jeylnn, and Janet are entitled to the SSS death benefits accruing from Pablo’s death.
  • Whether the verified public documents (e.g., birth certificates and confirmation reports by the civil registry) can conclusively establish the legitimacy of the children and thereby override conflicting testimonies regarding their paternity and legitimacy.
  • Whether evidence of Rosanna’s alleged extramarital relationship and de facto separation from Pablo sufficiently negates her status as a “dependent spouse” eligible for primary benefits under Section 8(e) and 8(k) of the SSS Law.
  • The extent to which the administrative and quasi-judicial findings (by the SSC) may be revisited and corrected by the Court based on the evidence of fact on record.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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