Case Summary (G.R. No. 186279)
Applicable Law
The claims for retirement benefits are governed by Republic Act No. 1516, as amended by Republic Act No. 4986, effective since July 12, 1976. The distribution of benefits is further informed by civil law principles surrounding intestate succession.
Claims for Retirement Benefits
Atty. Chanliongco had completed more than 38 years of service and was over 63 years of age at the time of his passing. He had no pending criminal or administrative cases and was not financially accountable for any money or properties. The claims for benefits comprise retirement benefits, terminal leave payment, life insurance, and refund of retirement premiums. The Government Service Insurance System (GSIS) had disbursed the life insurance proceeds and the refund of retirement premiums.
Distribution of Retirement Benefits
Due to Atty. Chanliongco’s oversight in failing to designate beneficiaries in his GSIS membership application, his retirement benefits were to be allocated according to intestate succession. The court upheld the GSIS determination regarding the retirement gratuity, which amounted to P7,140.10. Legal heirs and their respective shares were identified: 8/16 share to Mario II, 4/16 share to Dra. Fidela, and 2/16 shares to each of the two illegitimate children.
Terminal Leave Payment Breakdown
In addition to the retirement gratuity, the court addressed the money value of Atty. Chanliongco’s terminal leave, alongside unpaid salaries and a 10% adjustment. The Finance Officer provided a detailed breakdown, resulting in a net amount of P13,505.45 after deductions for withholding tax and outstanding loans. This net amount was to be distributed among the claimants based on their legal standing.
Distribution of Terminal Leave and Salary Benefits
The distribution of terminal leave benefits was treated as conjugal property, thus allocating half to Dra. Fidela and distributing the other half among the legal heirs as per the same proportions established for the retirement benefits. The final amounts allocated were provided explicitly for each claimant, totaling P78,140.10 for
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Case Background
- The case revolves around the claims for retirement benefits filed by the heirs of the late Atty. Mario V. Chanliongco, who served as an attorney for the Court.
- Atty. Chanliongco passed away on July 12, 1976, at the age of over 63, after more than 38 years of service in the government.
- At the time of his death, he had no pending criminal, administrative, or disbarment cases, nor any money or property accountability.
- His highest monthly salary was P18,700.00.
Claimants
- The claimants include his widow, Dra. Fidela B. Chanliongco, and his only legitimate son, Mario B. Chanliongco II.
- Additionally, two illegitimate children, Ma. Angelina C. Buenaventura and Mario Chanliongco, Jr., both recognized by the deceased, also filed claims.
- Except for Mario Jr., who is 17 years old, all other claimants are of legal age.
Types of Benefits
- The benefits accruing to Atty. Chanliongco include:
- Retirement benefits
- Money value of terminal leave
- Life insurance proceeds
- Refund of retirement premiums
- The Government Service Insurance System (GSIS) had already released the life insurance proceeds and refund of retirement premiums to the claimants.
Distribution of Retirement Benefits
- Atty. Chanliongco died intestate and did not name any beneficiaries in his GSIS application for retirement benefits.
- Consequently, the retirement benefits will be distributed according to the law on intestate succession, similar to the distribution of life insurance proceeds when no beneficiary is designated.
- The GSIS determined the amount of retirement gratuity and the respective shares of the legal heirs, which are as follows:
- Total creditable service: 37.57169 yea