Case Summary (G.R. No. 209741)
Antecedents of the Case
Edna and Edgardo were married on June 19, 1992, at the Regional Trial Court in Legazpi City, Albay. They had six children between 1985 and 1999. Edgardo designated Edna and their three older children as beneficiaries in a Form E-4 submitted to the SSS in 1994, and subsequently listed his three younger children as additional beneficiaries in a later form submitted in 2001. However, Edgardo had also previously submitted another Form E-4 on November 5, 1982, naming a different set of beneficiaries: his first wife, Rosemarie Azote, and one dependent child.
Initial Claim and Denial
After Edgardo’s death, Edna filed a claim for death benefits, but the SSS denied her application based on conflicting beneficiary designations. The SSC concluded that Edgardo’s marriage to Edna was invalid as his earlier marriage to Rosemarie had not been annulled or dissolved, and thus Edna was not recognized as the legal spouse entitled to the benefits.
Petition and Resolution
Edna appealed the SSC’s denial, asserting her legitimate marriage to Edgardo. Despite initial proceedings, the SSC upheld its denial of benefits, stating it was Edna's responsibility to prove the validity of her marriage. The SSC's position maintained that Rosemarie, as Edgardo's first wife, had not been declared legally dead and therefore, Edgardo’s second marriage lacked legal standing.
Court of Appeals Decision
The Court of Appeals (CA) later reversed the SSC's ruling, stating the SSC could not determine the validity of Edna’s marriage without contest from Rosemarie or her representatives. The CA recognized Edna's substantial evidence, including their marriage certificate and the baptismal certificates of her children, as sufficient proof of her entitlement to benefits. The CA ruled that Edgardo's later designation of Edna as wife-beneficiary in 1994 revoked his earlier designation of Rosemarie.
SSC's Argument
The SSC later petitioned for a review of the CA’s decision, arguing that it was entitled to determine the validity of marriages under its quasi-judicial powers for adjudicating benefit claims. The SSC maintained that Edna could not be considered a legitimate spouse eligible for benefits due to Edgardo’s unannulled first marriage. It contended that designating Edna as a beneficiary was invalid as Edgardo had not resolved the legal issues of his first marriage before marrying Edna.
The Court’s Ruling
The Supreme Court ruled in favor of the SSC and granted its petition, reaffirming the earlier determination that Edna was not the legal spouse of Edgardo due to the ongoing validity of his first
...continue readingCase Syllabus (G.R. No. 209741)
Background of the Case
- The case involves a petition for review on certiorari filed by the Social Security Commission (SSC) against Edna A. Azote regarding her claim for death benefits as the widow of Edgardo Azote.
- Edgardo Azote, a member of the Social Security System (SSS), was married to Edna on June 19, 1992, and they had six children together.
- Edgardo had previously submitted beneficiary designation forms (Form E-4) to the SSS, initially designating a different individual, Rosemarie Azote, as his spouse before later updating his beneficiaries to include Edna and their children.
- Edgardo passed away on January 13, 2005, after which Edna filed a claim for death benefits.
SSC's Denial of Benefits
- The SSC denied Edna’s claim, stating that Edgardo's earlier marriage to Rosemarie, which was registered in 1982, had not been annulled or dissolved, rendering Edna’s marriage invalid.
- The SSC maintained that Edna needed to prove the validity of her marriage to Edgardo to qualify for the benefits.
- The SSC's resolution cited that Rosemarie was presumed to still be Edgardo's legal wife, and thus Edna could not claim the benefits.
Court of Appeals' Decision
- The Court of Appeals (CA) reversed the SSC's decision, asserting that the SSC could not determine the validity of Edna's marriage without a challenge from Rosemarie or Elmer (the designated dependent).
- The CA acknowledged Edna's substantial evidence for her claim, including their marriage certificate and the baptismal certificates of their children.
- The CA further ruled that Edgardo's 1