G.R. No. 208567 - Manalo vs. TNS Philippines, Inc.

Clemente G. Bailon (Bailon) and Alice P. Diaz (Alice) married on April 25, 1955 in Barcelona, Sorsogon.
On October 9, 1970, Bailon filed a petition before the Court of First Instance (CFI) of Sorsogon to declare Alice presumptively dead.
On December 10, 1970, the CFI granted the petition, declaring Alice presumptively dead for all legal intents and purposes except succession.

On August 8, 1983, Bailon contracted marriage with respondent Teresita Jarque (respondent) in Casiguran, Sorsogon.
Bailon was a member of the Social Security System (SSS) since 1960 and a retiree pensioner effective July 1994.
Bailon died on January 30, 1998.

Respondent filed a claim for funeral benefits and was granted ₱12,000 by the SSS.
On March 11, 1998, respondent filed an additional claim for death benefits, which was also granted.
Cecilia Bailon-Yap (Cecilia), claiming to be Bailon’s daughter with Elisa Jayona (Elisa), contested the release of benefits to respondent, alleging:

Bailon contracted three marriages: first with Alice, second with Elisa, third with respondent, all alive.
Cecilia and siblings paid for Bailon’s medical and funeral expenses; respondent’s documents are spurious.

Cecilia and Norma Bailon Chavez submitted an affidavit stating they are children of Bailon and Elisa, and reserved the right to contest respondent’s marriage.
Hermes P. Diaz, claiming to be brother and guardian of Aliz P. Diaz (Alice), filed a claim for death benefits and attested that Norma defrayed funeral expenses.
Elisa and seven children submitted claims as beneficiaries.

Cancellation of death pension benefits to respondent and refund of amounts received.
Denial of claim of Alice on dependency grounds.
Payment of remaining pension to Bailon’s beneficiaries per law after recovery from respondent.

Legal opinion stated Alice never disappeared; the December 10, 1970 CFI order did not become final due to her “presence.”
Bailon was found to be the deserting spouse; marriage with respondent was void as bigamous.

August 16, 2000 letter advised respondent to return funeral benefit payment.
September 7, 1999 letter notified cancellation of death pension benefits on grounds that respondent's marriage was void and requested refund of ₱24,000.
Respondent protested the cancellation and requested restoration of pension benefits.
SSS maintained denial but informed right to file petition with Social Security Commission (SSC).

Respondent filed petition before SSC for restoration of pension.
Alicia P. Diaz (Alice) filed affidavit asserting she was alive and had not disappeared, living in Barcelona after separation.
On April 2, 2003, SSC resolved respondent was not the legitimate spouse but a common-law wife; ordering refund of death and funeral benefits, and directing payment to Alice.
SSC found the 1970 CFI order declaring Alice presumptively dead was obtained by fraud, did not authorize Bailon’s remarriage, and that Bailon abandoned Alice.
Respondent’s motion for reconsideration was denied on June 4, 2003.

Respondent appealed to Court of Appeals (CA).
On June 23, 2004, CA reversed SSC decisions and ordered SSS to pay respondent all pension benefits due.
CA held the SSC cannot review or overrule the RTC’s order declaring Alice presumptively dead and cannot declare the second marriage void; only a competent court can annul marriages.
SSC and SSS motions for reconsideration were denied.
SSS filed the present petition for review on certiorari, alleging errors by the CA.

Whether the SSC may validly review and reverse the CFI (RTC) Order declaring Alice presumptively dead and subsequently declare the marriage between Bailon and respondent null and void.
Whether the marriage between Bailon and respondent is valid and whether respondent is entitled to SSS death and funeral benefits as Bailon's surviving spouse.
Whether the CA gravely abused its discretion in ruling for respondent without due consideration of the SSC’s findings and SSS’s discretionary authority.
Whether the cancellation of respondent’s pension benefits and demand for refund violated due process.