Facts:
On December 28, 1961, the Supreme Court resolved an appeal by
Jose P. Tecson from a ruling of the
Social Security Commission denying payment of
death benefits. The appeal arose from the claim of Tecson, who had been designated as beneficiary by the late
Lim Hoc, a former employee of the
Yuyitung Publishing Company. Lim Hoc died on November 3, 1957, while he was a member of the
Social Security System, having qualified on September 1, 1957. In his
SSS Form E-1, Lim Hoc declared that he was
married but made no mention of any members of his family or other relatives. Instead, he designated Tecson—reported as his friend and co-worker—as his beneficiary. After Lim Hoc’s death, Tecson filed with the System a claim for death benefits in his capacity as designated beneficiary. The Social Security Commission found that, at the time the claim was decided, it was subsequently known that Lim Hoc had a wife and children in Communist China, yet he had not reported them in the records available to the employer and the System. The Commission ruled that Tecson could not be paid because the legislative policy behind the System is to protect the covered employee and his
family, and it reasoned that, under the Social Security Act, the beneficiary recorded by the employer must be among those properly covered in the System’s rules and regulations; it concluded that Lim Hoc’s omission of his wife and children indicated that they were not dependents or, alternatively, that Tecson was improperly designated to the exclusion of the employee’s family.
Issues:
Did the Social Security System and the Social Security Commission commit reversible error when they denied
death benefits to
Jose P. Tecson, despite his designation as beneficiary in the employee’s records?
Ruling:
Ratio:
Doctrine: