Case Summary (G.R. No. L-44059)
Petitioner and Respondent
Appellant: Carponia T. Ebrado (defendant-appellant below) — claimed proceeds as designated beneficiary. Appellee/Plaintiff: The Insular Life Assurance Co., Ltd. — brought interpleader action due to competing claims. Other claimant/respondent below: Pascuala Vda. de Ebrado (legal wife) — asserted entitlement as the lawful spouse.
Key Dates (selected)
Policy issued: September 1, 1968. Death of insured: October 21, 1969 (accidental). Interpleader filed by insurer: April 29, 1970. Pre-trial and stipulated facts: July 8, 1972. Trial court judgment: September 25, 1972. Appellate court certification to the Supreme Court: July 11, 1976.
Applicable Law and Legal Framework
Primary instruments and provisions considered by the Court in its reasoning: the Insurance Act (RA 2327, as amended) and the Insurance Code (PD No. 612) for the narrow insurance-law context; the New Civil Code — specifically Article 739 (proscribing certain donations) and Articles 2011–2012 (mandating that matters not covered by special laws are governed by the Civil Code and providing that those forbidden to receive donations under Article 739 cannot be named beneficiaries of life insurance policies). The Court also relied on prior jurisprudence equating life insurance beneficiaries with donees and on principles allowing proof by preponderance in civil actions concerning disqualifying illicit relationships.
Material Facts
Ebrado purchased a whole-life insurance policy with an accidental death rider for identical face amounts; he designated Carponia as revocable beneficiary and referred to her as his wife. At the time of the policy and of his death, Ebrado remained legally married to Pascuala and had six legitimate children with her; concurrently, he lived with Carponia and had two children with her. Upon his accidental death, both Carponia and Pascuala asserted claims to the policy proceeds, prompting the insurer to file an interpleader action and deposit the proceeds in dispute.
Procedural Posture and Stipulation
During pre-trial the parties stipulated to the key facts summarized above and expressly agreed that resolution could be rendered on the basis of those stipulations. The trial court entered judgment declaring Carponia disqualified from receiving the proceeds and ordered the amount paid to the deceased’s estate; Carponia appealed, and the Court of Appeals certified the case to the Supreme Court as presenting only questions of law.
Legal Issue Presented
Whether a person living in a common-law conjugal relationship with a legally married insured, who has been designated as beneficiary in the insured’s life insurance policy, may lawfully receive the policy proceeds, or whether such designation is void by force of the Civil Code provision disqualifying persons guilty of adultery or concubinage from receiving donations from the spouse or consort.
Court’s Legal Analysis — Applicability of Insurance Law vs. Civil Code
The Court recognized that neither the Insurance Act nor the Insurance Code expressly resolves the particular question; the general provision that insurance proceeds shall be applied exclusively to the proper interest of the insured does not itself determine the status of beneficiaries. Article 2011 of the Civil Code requires that matters not expressly provided for in special laws be governed by the Code; Article 2012 states that individuals forbidden from receiving donations under Article 739 cannot be named beneficiaries of life insurance policies by the person who cannot make such donations. Consequently, the Court applied the civil-law rules on donations to life insurance beneficiary designations.
Analogy Between Beneficiary and Donee; Application of Article 739
The Court treated a life insurance beneficiary as analogous to a donee because both receive a benefit founded on the insured’s liberality (premiums paid by the insured). Under Article 739(1), donations between persons guilty of adultery or concubinage at the time of the donation are void; the Court extended this disability to life insurance beneficiary designations, concluding that a person living in concubinage with a married insured falls within the proscription and therefore is disqualified from being a beneficiary.
Quantum and Mode of Proof for Disqualification
The Court emphasized that Article 739 itself contemplates civil proof: a criminal conviction is not a prerequisite. The law allows the disqualifying guilt of the donee (here, beneficiary) to be established by a preponderance of evidence in the civil proceeding regarding the nullity of the donation. Where the parties have judicially admitted the existence of the illicit relationship (as in the stipulation at pre-trial), no further criminal or independent civil finding is required; judicial admissions are conclusive and suffice to support a judgment of disqualification.
Policy and Moral Considerations
The Court e
Case Syllabus (G.R. No. L-44059)
Title, Citation and Court
- 170 Phil. 265, First Division.
- G.R. No. L-44059.
- Decision dated October 28, 1977.
- Opinion by Justice Martin.
- Concurring: Teehankee (Chairman), Makasiar, Munoz Palma, Fernandez, and Guerrero, JJ.
Procedural History
- Insular Life Assurance Co., Ltd. issued Policy No. 009929 (whole-life plan with accidental death rider) to Buenaventura Cristor Ebrado on September 1, 1968.
- Upon the insured's death (October 21, 1969), two claimants emerged: Carponia T. Ebrado (designated revocable beneficiary who lived with the insured as his common-law wife) and Pascuala Vda. de Ebrado (the lawful wife).
- Insular Life, uncertain as to the proper payee, filed an action of Interpleader in the Court of First Instance of Rizal on April 29, 1970.
- Pre-trial conference held July 8, 1972; parties submitted evidence and entered stipulations; court ordered simultaneous memoranda.
- Trial court rendered judgment on September 25, 1972 declaring the common-law wife, Carponia T. Ebrado, disqualified from being beneficiary and directing payment of proceeds to the estate of the deceased insured.
- Carponia T. Ebrado appealed to the Court of Appeals; on July 11, 1976 the Court of Appeals certified the case to the Supreme Court as involving only questions of law.
- Supreme Court affirmed the trial court judgment on October 28, 1977.
Facts (Agreed and Stipulated)
- The insured: Buenaventura Cristor Ebrado.
- Policy: No. 009929, whole-life plan dated September 1, 1968, face amount P5,882.00; accidental death rider for an additional P5,882.00.
- Designated beneficiary: Carponia T. Ebrado (designated as revocable beneficiary; insured referred to her as his wife).
- The insured died on October 21, 1969 by accident (struck by a falling tree branch); death evidenced by death certificate (Exhibit 3) and police report affidavit (Exhibit 5).
- Insurer's aggregate liability: P11,745.73, described as face value P5,882.00 + accidental death benefit P5,882.00 + refund P18.00 for premium due November 1969, less unpaid premiums and interest for January and February 1969 in the sum of P36.27.
- Family status agreed: the insured was legally married to Pascuala Ebrado and had six legitimate children (Hernando, Cresencio, Elsa, Erlinda, Felizardo and Helen, all surnamed Ebrado).
- Extra-marital relationship agreed: during his lifetime the insured was living with Carponia Ebrado as husband and wife without legal marriage and had two children with her; the legal marriage was not dissolved.
- The parties stipulated that the insured reserved the option to change the beneficiary but did not effect any change prior to death; the legal wife did not have opportunity to write the company regarding any reservation to change designation.
- The parties agreed that a decision be rendered based on the agreement and stipulation of facts as to who among the two claimants is entitled to the policy.
Issues Presented
- Primary legal issue: Can a common-law wife, who was named as revocable beneficiary in the life insurance policy of a legally married man, claim the proceeds of that policy upon his death?
- Subsidiary questions implicit in the proceedings:
- Whether the statutory and codal prohibitions on donations between persons guilty of adultery or concubinage apply to life insurance beneficiary designations.
- Whether criminal conviction for adultery or concubinage is a prerequisite to disqualify a donee/beneficiary under Article 739.
- Whether judicial admissions/stipulations at pre-trial suffice to establish the illicit relationship and thus disqualification.
Relevant Statutes, Code Provisions and Doctrinal Statements (as cited)
- Insurance Act (RA 2327) and Insurance Code (PD No. 612) contain no express provision resolving the primary question; Section 50 of the Insurance Act (cited) and Section 53 of PD 612 (footnote) referenced:
- Section (Insurance Act): "(t)he insurance shall be applied exclusively to the proper interest of the person in whose name it is made." (Court notes this cannot be validly seized upon to include the beneficiary.)
- Footnote: Sec. 53 of PD 612: "The insurance proceeds shall be applied exclusively to the proper interest of the person in whose name or for whose benefit it is made unless otherwise specified in the policy."
- New Civil Code:
- Article 2011: "The contract of insurance is governed by special laws. Matters not expressly provided for in such special laws shall be regulated by this Code."
- Article 2012: "Any person who is forbidden from receiving any donation under Article 739 cannot be named beneficiary of a life insurance policy by the person who cannot make a donation to him."
- Article 739 (tex