Case Digest (G.R. No. L-15798)
Facts:
Jose P. Tecson v. Social Security System, G.R. No. L-15798, December 28, 1961, the Supreme Court En Banc, Labrador, J., writing for the Court.
Petitioner Jose P. Tecson sought payment of death benefits from respondent Social Security System (SSS) as the designated beneficiary of Lim Hoc, an employee of the Yuyitung Publishing Company. The Social Security Commission had denied Tecson’s claim.
The Commission found that Lim Hoc became an SSS member on September 1, 1957, and died on November 3, 1957. In the SSS Form E-1 that Lim Hoc filed, he stated his civil status as married but did not list any family members or dependents; instead he designated Tecson, described as a friend and co-worker, as his beneficiary. After Lim Hoc’s death, Tecson filed a claim for death benefits as the designated beneficiary.
The Social Security Commission denied Tecson’s claim. The Commission construed the statutory scheme and its regulations to mean that a covered employee may designate as beneficiary only persons of the kinds enumerated in its rules and that beneficiaries must have been recorded in the System’s records prior to the employee’s death. The Commission also relied on employer reporting duties under Sections 23 and 24 of Republic Act No. 1161 (as amended) and on Rule 7(3)(a) of the SSS rules enumerating permissible beneficiaries. It noted that, although Lim Hoc had listed himself as married, later information showed he had a wife and children in Communist China; the Commission concluded the omission from employer records indicated non-dependency or lack of prior report and treated Tecson’s designation as not displacing the scheme favoring relatives and reported dependents.
Petitioner appealed the Commission’s ruli...(Pro-only)
Issues:
- Whether petitioner Jose P. Tecson, as the person designated by the deceased in the SSS Form E-1, is entitled to death benefits under Republic Act No. 1161 (as amended) despite the existence of the decedent's wife and children abroad who were not recorded with the employer.
- Whether the Social Security Commission properly refused payment on the ground that only the enumerated relatives may be beneficiaries and that employer reporting of dependents precl...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)