Case Summary (G.R. No. 250613)
Applicable Law
The case is guided by pertinent laws under the 1987 Philippine Constitution, the Family Code, and the New Civil Code, specifically concerning the validity of marriages, the rights of heirs, and the distribution of estates.
Factual Antecedents
The case concerns the distribution of Pedrito's death benefits, amounting to PHP 4,506,309.52, after his demise on June 26, 2015. He was initially married to Cerena N. Macalinao in 1981, with whom he had one child, Cindy. Following a four-year separation, he married Elenita V. Macalinao in 1990, and they had two children, Kenneth and Kristel. The legal proceedings began when Cerena and Cindy sought to declare Pedrito's marriage to Elenita void due to bigamy, which was subsequently affirmed by the Regional Trial Court (RTC).
RTC Decision
In the RTC's September 12, 2018 decision, it was ruled that Pedrito's marriage to Elenita was null and void due to its bigamous nature. Consequently, it stated that Kenneth and Kristel were illegitimate children, while Cindy was legitimate. The death benefits were found to form part of Pedrito's estate, with Cerena entitled to one-half as the legal spouse and the remaining half to be divided among all three children.
Court of Appeals Decision
The Court of Appeals affirmed the RTC's decision, reiterating the validity of Cerena's marriage to Pedrito and dismissing any claims by Elenita regarding the death benefits. The court determined that Pedrito's death was indeed work-related under the Philippine Overseas Employment Administration (POEA) rules and highlighted the legal implications of both the marriages in determining the rightful beneficiaries.
Supreme Court's Ruling
Upon review, the Supreme Court ruled that while the death benefits are to be distributed in accordance with the rules on compulsory succession, they should not be treated as part of Pedrito's estate. Instead, the benefits are directly payable to the beneficiaries, guided by the principles of the New Civil Code. The Court ruled that Cerena, as the legal spouse and unlike Elenita due to her bigamous marriage, along with the three children, would share in the distribution of these benefits.
Distribution of Death Benefits
The Court established that Cerena would receive one-fourth of the total benefits since she is a legal spouse, and Cindy would receive one-half as the legitimate child. The two illegitimate ch
Case Syllabus (G.R. No. 250613)
Background and Procedural History
- This case arises from a petition for review on certiorari under Rule 45 challenging the decision and resolution of the Court of Appeals dated August 29, 2019, and November 25, 2019, respectively, which denied the appeal of petitioners and affirmed the decision of the Regional Trial Court (RTC) Branch 207, Muntinlupa City.
- The underlying issue concerns the rightful claimants to the death benefits of Pedrito G. Macalinao, a deceased seafarer.
- The controversy involves two marriages of Pedrito: the first to Cerena in 1981, with whom he had one child, Cindy, and the second bigamous marriage to Elenita in 1990, with whom he had two children, Kenneth and Kristel.
Facts
- Pedrito and Cerena married legally in 1981 and had one child, Cindy; they separated in fact around 1985.
- Pedrito married Elenita in 1990 without nullity of the first marriage, thus rendering the second marriage bigamous and void.
- Pedrito worked as a seafarer for Excel Marine Co. Ltd./Fair Shipping Corporation and died in 2015.
- His death benefits amounted to USD 93,057.88 (PHP 4,506,309.52).
- Cerena and Cindy filed a petition initially for the declaration of nullity of the second marriage but later amended it to a petition for settlement of Pedrito’s estate.
- Excel Marine deposited the death benefits with the RTC as full settlement.
Issue Presented
- Whether the death benefits form part of Pedrito’s estate subject to intestate succession.
- How and among whom the death benefits should be distributed considering the two marriages and their respective children.
Lower Courts’ Rulings
- The RTC declared the marriage between Pedrito and Elenita null and void for bigamy.
- It recognized Cerena as the legitimate surviving spouse and the children from the first marriage as legitimate; Kenneth and Kristel were declared illegitimate.
- RTC ruled that the death benefits form part of Pedrito’s estate and should be distributed under the New Civil Code succession rules: half to Cerena as conjugal share and the other half divided among Cerena and all children.
- The Court of Appeals affirmed the RTC decision.
Supreme Court’s Ruling – The Nature of Death Benefits
- Death benefits do not form part of the hereditary estate since they arise only upon the death of the seafarer.
- They are contractual death benefits payable directly to beneficiaries, not inheritance.
- POEA Memorandum Circular defines beneficiaries as those payable under civil law rules of succession, but this does not make death benefits part of estate.
- Death benefits are exempt from estate tax under Republic Act No. 4917.