Case Summary (G.R. No. L-44059)
Legal Issue
Can a common-law spouse, living in concubinage with an insured who is legally married to another, validly be named and qualified as beneficiary under a life insurance policy?
Trial Court Ruling
The Court of First Instance held that Carponia was disqualified under Article 739 of the Civil Code—which voids donations between persons guilty of adultery or concubinage at the time of donation—and ordered the proceeds paid to the insured’s estate.
Supreme Court Analysis
- Insurance contracts are governed by special legislation; in gaps, the Civil Code applies (Art. 2011).
- Article 2012 explicitly extends the prohibitions on donations (Art. 739) to life insurance beneficiaries: “any person who is forbidden from receiving any donation … cannot be named beneficiary of a life insurance policy.”
- A beneficiary under a life policy is analogous to a donee in a civil donation—both receive gratuitous liberalities from the insured/donor.
- Article 739 voids donations between persons in concubinage at the time of donation; no criminal conviction is required, as guilt may be proven by a preponderance of evidence in the same proceeding.
- The pre-trial stipulation constituted judicial admissions that the insured and Carponia were in concubinage while still married to Pascuala, satisfying the proof requirement.
- Public policy and moral considerations support barring illicit unions from p
Case Syllabus (G.R. No. L-44059)
Facts
- On September 1, 1968, The Insular Life Assurance Company, Ltd. issued Policy No. 009929, a whole-life plan with a P5,882 face value and an accidental death rider of P5,882, to Buenaventura Cristor Ebrado.
- Ebrado designated Carponia T. Ebrado as the revocable beneficiary, referring to her as his “wife.”
- On October 21, 1969, Ebrado died in an accident when struck by a falling tree branch.
- As of his death, the policy was in force and the total proceeds due amounted to P11,745.73 (face value plus accidental death benefits plus a P18 premium refund, less unpaid January–February 1969 premiums and interest).
- Carponia, admitting she was Ebrado’s common-law wife, filed a claim as the named beneficiary.
- Pascuala Vda. de Ebrado, the insured’s legal wife and mother of six legitimate children, also claimed the proceeds.
- The insurer, uncertain which claimant was entitled, filed an interpleader action in the Court of First Instance of Rizal on April 29, 1970.
- At a July 8, 1972 pre-trial conference, parties stipulated nine factual points, including:
- Ebrado’s valid marriage to Pascuala and their six legitimate children.
- Ebrado’s cohabitation with Carponia, producing two children, while still married to Pascuala.
- The policy’s terms, beneficiary designation, and lack of any effective change of beneficiary.
- The precise amount due under the policy.
- The agreement that decision would rest on these stipulated facts.
Procedural History
- The trial court rendered judgment on September 25, 1972:
- Declared Carponia disqualified as beneficiary under Article 739 of the Civil Code.
- Ordered po