G.R. No. 165546 - Social Security System vs. Aguas

Case Summary (G.R. No. 165546)

SSS investigation and evidentiary material

The SSS investigation produced witness interviews and medical information suggesting Pablo was infertile and that Rosanna had children with Romeo dela Peña. The SSS also obtained copies of birth and baptismal certificates (including a birth certificate for a Jefren H. dela Peña indicating a parental marriage between Rosanna and Romeo on November 1, 1990) and obtained confirmation reports from civil registries verifying marriage and birth entries. The SSS laboratory analysis authenticated Pablo’s signature on Jeylnn’s birth certificate as matching his specimen signatures on SSS records.

Proceedings and findings before the Social Security Commission (SSC)

Rosanna and the children filed for restoration/payment of pensions with the SSC. The SSC set hearings, summoned witnesses (neighbors and relatives), and required the SSS to verify documentary entries. Testimonies and documentary evidence produced conflicting accounts: some witnesses (Vivencia Turla, Carmelita Yangu) claimed the spouses lived together until Pablo’s death and identified Jeylnn and Janet as Pablo’s children; other witnesses (Leticia, Mariquita, Jessie) testified that Rosanna separated from Pablo years earlier, cohabited with Romeo dela Peña, and that Jeylnn and a Jenelyn dela Peña were the same child bearing Romeo as father. Baptismal certificates and parish records introduced at the hearing suggested irregularities, including two baptismal records with different names and dates that could indicate an attempt to recharacterize the child’s parentage.

SSC decision and rationale

The SSC denied the claimants’ petition. It concluded that Rosanna was no longer a qualified primary beneficiary because she had contracted marriage with Romeo during the subsistence of her marriage to Pablo (as evidenced by the birth certificate of Jefren H. dela Peña) and had a child by Romeo while still married to Pablo, thereby becoming ineligible for support from Pablo due to adultery and separation. The SSC further concluded that Jeylnn was not demonstrably Pablo’s legitimate child, finding more persuasive evidence that Jeylnn and Jenelyn were the same person and that the latter was the child of Rosanna and Romeo. The SSC also found Janet to be only an adopted child without any legal adoption papers, disqualifying her as a primary beneficiary.

Court of Appeals holding

The CA reversed the SSC, declaring petitioners (Rosanna, Janet, Jeylnn) entitled to SSS benefits. The CA relied predominantly on the birth certificates of Janet and Jeylnn that listed Pablo as father, treating those public records as binding and not susceptible to being altered or negated by witness testimony outside a judicial proceeding. The CA further held that there was insufficient evidence to show Rosanna ceased receiving support from Pablo prior to his death, and that even if she married Romeo during her marriage to Pablo the resulting marriage would be void and would not automatically negate dependency.

Issues presented to the Supreme Court

The core issues were (1) whether Rosanna qualified as a primary beneficiary as “legitimate spouse dependent for support” under Section 8(e) and (k) of the SSS law, and (2) whether Janet and Jeylnn were legitimate children of Pablo entitled to primary beneficiary status and corresponding death benefits.

Legal standards applied by the Supreme Court

The Court affirmed that claims to SSS benefits require proof by substantial evidence. It reiterated the statutory definitions: a dependent spouse must be a legitimate spouse actually dependent for support; primary beneficiaries are the dependent spouse and dependent children. The Court applied the presumption of legitimacy under Article 164 of the Family Code — that children conceived or born during marriage are legitimate — and noted the circumstances under which that presumption may be rebutted (physical impossibility of access, separation preventing intercourse, or serious illness). The Court also observed the limits of Rule 45 review: ordinarily confined to questions of law, but the Court may review factual findings where the CA’s findings are premised on misapprehension of facts or contradicted by the record.

Supreme Court analysis on the legitimacy of Jeylnn and Janet

The Court found that Jeylnn established entitlement to a monthly pension. Her birth certificate bore Pablo’s signature, and the civil registry confirmed her birth date; given that she was born during the marriage of Pablo and Rosanna, the Family Code presumption of legitimacy applied and was not rebutted by a challenge from Pablo during his lifetime. The Court emphasized that a father’s signature on a birth certificate is competent evidence of paternity and that the presumption of legitimacy becomes conclusive in the absence of timely contestation by the husband or heirs.

Conversely, Janet’s birth certificate was presented only as an unverified photocopy and lacked confirmation by the civil registry, thus lacking substantive probative weight. Witnesses uniformly testified Janet was merely taken in or informally adopted, and there were no legal adoption papers. Under Section 8(e) of the SSS law only “legally adopted” children qualify as dependent children. Consequently, Janet failed to establish entitlem

Case Syllabus (G.R. No. 165546)

Procedural History and Posture

Petition for review on certiorari under Rule 45 of the Rules of Court from the Court of Appeals decision in CA-G.R. SP No. 66531 and its denial of motion for reconsideration.
Original administrative proceedings began when Pablo Aguas, an SSS member and pensioner, died on December 8, 1996; his surviving spouse Rosanna H. Aguas filed a claim for death benefits on December 13, 1996.
SSS settled the monthly pension payment on February 13, 1997 but, after receiving a complaint and conducting investigation, suspended payments in September 1997 and directed refund of P10,350.00 to Rosanna for amounts paid from December 1996 to August 1997 (P1,150.00 per month).
Rosanna and Jeylnn (and later Janet) filed for reconsideration with the SSS; denial followed (Letter dated February 6, 1998).
Claimants filed petition for Restoration/Payment of Pensions with the Social Security Commission (SSC) on February 20, 1998 (SSC Case No. 3-14769-98); SSC conducted hearings and evidence-gathering; SSC rendered decision denying claims on March 14, 2001 and ordered refund of P10,350.00 and payment to qualified secondary beneficiaries or legal heirs.
Petitioners appealed to the Court of Appeals which, on September 9, 2003, reversed and set aside the SSC decision and declared petitioners entitled to SSS benefits; remanded to SSS for computation of benefits accruing after suspension.
SSS filed motion for reconsideration in CA which was denied; SSS then filed this petition before the Supreme Court.
Supreme Court issued decision on February 27, 2006: petition partially granted; CA decision affirmed with modification — only Jeylnn H. Aguas declared entitled to death benefits.

Core Facts

Member/pensioner Pablo Aguas died December 8, 1996.
Surviving spouse Rosanna H. Aguas filed death benefit claim December 13, 1996 indicating a minor child, Jeylnn (born October 29, 1991).
SSS released monthly pensions beginning February 13, 1997; later suspended in September 1997.
Leticia Aguas-Macapinlac (Pablo’s sister) sent a sworn letter dated April 2, 1997 alleging Rosanna abandoned the family more than six years earlier, lived with another man (Romeo dela PeAa), and that Pablo had no legal children with Rosanna.
Leticia enclosed a notarized copy of the original birth certificate of Jefren H. dela PeAa (born November 15, 1996) showing his parents as Rosanna Y. Hernandez and Romeo C. dela PeAa and showing their marriage on November 1, 1990.
SSS investigation (Memorandum dated November 18, 1997) reported interviews with Mariquita D. Dizon and Jessie Gonzales indicating Pablo had no legal children with Rosanna, that Jenelyn and Jefren were Rosanna’s children with Romeo, and that Rosanna left Pablo six years before his death and lived with Romeo while pregnant with Jenelyn.
Alleged confirmation by a certain Dr. Manuel Macapinlac that Pablo was infertile informed SSS decision; Dr. Macapinlac later denied being an expert on infertility and denied offering such an opinion.
SSS obtained civil registry confirmations for marriage (Pablo and Rosanna on December 4, 1977), births (Jefren Nov. 15, 1996; Jeylnn Oct. 29, 1991), and Pablo’s death (Dec. 8, 1996). SSS also conducted laboratory analysis verifying that the signature on Jeylnn’s birth certificate was made by the same person who signed Pablo’s member records.
Claimants submitted photocopies of marriage certificate of Pablo and Rosanna, and photocopies of Janet’s and Jeylnn’s certificates of live birth and Pablo’s death certificate.
Witnesses: Vivencia Turla and Carmelita Yangu (neighbors) executed joint affidavit and testified that Rosanna and Pablo lived together as husband and wife until Pablo’s death and that Jeylnn was their real child; Leticia, Mariquita, and Jessie testified otherwise, recounting separation, alleged adultery, and that Janet was not a biological child but taken in by Pablo and Rosanna (no legal adoption papers).
Baptismal certificates were produced during hearings: Jeylnn Aguas baptized November 24, 1991 as child of Pablo and Rosanna; Jenelyn H. dela PeAa born January 29, 1992 and baptized February 9, 1992 as child of Rosanna and Romeo — SSC observed that the two baptismal certificates indicate Jeylnn and Jenelyn might be the same person with altered baptismal record and date of birth.

Issues Presented

Whether Rosanna H. Aguas qualifies as a “dependent spouse” and thus a primary beneficiary under Section 8(e) and Section 8(k) of Republic Act No. 1161, as amended.
Whether Janet H. Aguas and Jeylnn H. Aguas are legitimate children of Pablo Aguas entitled to death benefits as primary beneficiaries.
Whether the SSC and SSS, in exercising quasi-judicial authority, properly assessed legitimacy and dependency without judicial correction of public records.
Whether entries in public records (birth certificates, baptismal records) bind parties and may be challenged by testimonial evidence in administrative proceedings.

Petitioner’s (SSS) Contentions

Rosanna forfeited her right to support by engaging in an intimate and illicit relationship with Romeo dela PeAa and marrying him during her marriage to Pablo; such conduct constituted abandonment and adultery, divesting her of the right to receive support.
The birth certificate of Jefren H. dela PeAa (showing marriage of Rosanna and Romeo on November 1, 1990 and Jefren’s birth on November 15, 1996) evidences adultery and illegitimacy of claimed children by Pablo.
Janet and Jeylnn are not legitimate children of Pablo; testimonial evidence and documents collected during the SSS investigation show disqualification of claimants as primary beneficiaries.
The SSC, in its quasi-judicial capacity, may determine legitimacy for purposes of entitlement and need not await judicial correction of birth records.

Respondents’ (Claimants) Contentions

Jeylnn is legitimate as shown by her birth certificate bearing Pablo’s signature as father; the signature was genuine.
Rosanna never left Pablo and they lived together as husband and wife; affidavits of neighbors Vivencia Turla and Carmelita Yangu support continued cohabitation and dependence.
Janet’s birth certificate, registered in the Civil Registry of San Fernando, indicates Pablo as father and Rosanna as mother.
Dr. Macapinlac denied giving an opinion on Pablo’s infertility and was not an expert; communications with the doctor were privileged.
Legitimacy of children may be impugned only on grounds set in Article 166 of the Family Code; such grounds were not proven.

Applicable Statutes, Rules and Legal Standards

Republic Act No. 1161, as amended by Presidential Decree No. 735: definitions in Section 8 (e) Dependent; Section 8(k) Beneficiaries; Section 13 Death benefits and conditions for primary and secondary beneficiaries.
Family Code: Article 164 — presumption that children conceived or born during marriage are legitimate; Article 170 and Article 171 — periods and parties who may impugn legitimacy.
Article 195, Family Code — mutual obligation of support between spouses.
Standard of proof in administrative/quasi-judicial proceedings: entitlement must be shown by substantial evidence (relevant evidence which a reasonable mind might accept as adequate to justify a conclusion).
Precedents cited in the Court’s opinion establishing review standards and legal principles: Bank of the Philippine Islands v.