Case Summary (G.R. No. 181132)
Trial Court Ruling on Motion to Dismiss
Insular Life and Grepalife moved to dismiss for failure to state a cause of action, invoking Section 53 of the Insurance Code (proceeds paid exclusively to designated beneficiaries) and arguing that no estate settlement had been made to apply Civil Code legitime rules. The trial court granted the motion as to the three illegitimate children on September 21, 2004, holding that: insurance proceeds vest in named beneficiaries; Civil Code rules on donations and succession do not apply to insurance indemnities.
Trial Court Reconsideration and Dismissal of Petition
Upon motions for reconsideration by Insular Life and Grepalife, the trial court on June 16, 2005, dismissed the entire petition. It found that: (a) Eva’s designation had been revoked or she was disqualified, leaving only the illegitimate children as valid beneficiaries; (b) the Insurance Code governed distribution, rendering legitime claims inapplicable; and (c) Grepalife’s policy named only the illegitimate children and the misrepresentation issue was premature.
Appeal and Jurisdictional Ruling by the Court of Appeals
Petitioners appealed to the Court of Appeals, which dismissed for lack of jurisdiction, reasoning that the dismissal for failure to state a cause of action raised a pure question of law and that petitioners had allowed the September 21, 2004 resolution to attain finality by not moving for reconsideration.
Issues Raised on Certiorari
- Whether a motion to dismiss for failure to state a cause of action may consider defenses and facts outside the complaint.
- Whether the trial court improperly examined unproven facts when granting the motions for reconsideration of the dismissal.
- Whether legitimate heirs are entitled to insurance proceeds designated for a disqualified concubine beneficiary.
Supreme Court Analysis on Cause of Action
Under Rule 16, Section 1(g) of the Rules of Court, dismissal for failure to state a cause of action must rest solely on the complaint’s allegations, hypothetically admitted as true. Exceptions allow consideration of judicially noticeable facts, legally impossible allegations, inadmissible evidence, or documents of record. Here, the petition’s own allegations show petitioners were not named beneficiaries, and insurance contracts vested proceeds exclusively in designated beneficiaries.
Application of Insurance Code and Civil Code Provisions
- Section 53, Insurance Code: proceeds “applied exclusively to the proper interest of … for whose benefit [the policy] is made.”
- Article 2011, Civil Code: insurance governed by special laws (Insurance Code); Civil Code applies only where the Insurance Code is deficient.
- Article 739, Civil Code: forbids donations to concubines; however, disqualification of Eva does not vest proceed
Case Syllabus (G.R. No. 181132)
Facts and Parties
- Decedent Loreto C. Maramag left behind a surviving lawful spouse, Vicenta Pangilinan Maramag, and legitimate children who comprise the petitioners.
- Respondents include: Eva Verna de Guzman Maramag (Loreto’s concubine and suspect in his killing), their three minor children (Odessa, Karl Brian, and Trisha Angelie), Insular Life Assurance Company, Ltd. (Insular), and Great Pacific Life Assurance Corporation (Grepalife).
- Loreto procured two life insurance policies from Insular (Policy No. A001544070 for ₱1,500,000; No. 1643029 for ₱500,000) and three plans from Grepalife (two pension plans, PTLIG1000326-0000 for ₱1,000,000 and PTLIG1000344-0000 for ₱500,000; one memorial plan M0109-159064-0000 for ₱50,000).
- Petitioners alleged that Eva was disqualified as a beneficiary under Article 739 of the Civil Code for having caused Loreto’s death and that Odessa, Karl Brian, and Trisha Angelie, as illegitimate children, were entitled only to half the legitime of legitimate heirs.
- They sought revocation or reduction of insurance proceeds as void or inofficious, a temporary restraining order, a writ of preliminary injunction, and payment of ₱320,000 as litigation expenses and attorneys’ fees.
Procedural History
- The petition was filed in the Regional Trial Court (RTC), Branch 29, Manila. Summons by publication was resorted to when respondents’ whereabouts were unknown, resulting in the default of the illegitimate children.
- Insular’s Answer admitted Loreto’s misrepresentation of beneficiaries, disqualified Eva upon discovery of her status, paid Odessa’s share, and withheld minors’ shares pending guardianship letters. It moved to dismiss for failure to state a cause of action.
- Grepalife’s Answer denied any beneficiary designation for Eva, invoked Loreto’s age misrepresentation to deny benefits, and asserted the case was premature and not governed by succession law. It likewise moved to dismiss.
- On September 21, 2004, the RTC granted the insurers’ motion to