Case Summary (G.R. No. L-21642)
Facts of the Case
The main issue arises from the conflicting claims of the two wives regarding the entitlement to death benefits under the SSS. Petronilo Davac was married to Lourdes Tuplano on August 29, 1946, and had one child, Romeo Davac. He later married Candelaria Davac on January 18, 1949, with whom he had another child, Elizabeth Davac. After Petronilo's death, both wives filed claims for the death benefits, leading the SSS to request that the parties interplead and resolve the conflicting claims.
Social Security Commission's Resolution
On February 25, 1968, the Social Security Commission ruled in favor of Candelaria Davac, declaring her the rightful beneficiary. Lourdes Tuplano appealed this decision to a higher court, challenging the Commission’s conclusion.
Legal Framework
The decision is grounded in Section 13 of Republic Act No. 1161, as amended by Republic Act No. 1792, which stipulates that the benefits payable upon an employee's death are to be received by the designated beneficiary as recorded by the employee's employer. The provision was interpreted in a previous case, Tecson vs. Social Security System, which emphasized the clarity and explicit nature of the law's provisions regarding beneficiary eligibility.
Arguments of the Appellant
Lourdes Tuplano contends that the designation of Candelaria as a beneficiary is void due to her status as Petronilo's second wife in a bigamous marriage. She argues that this designation violates the Civil Code, specifically Article 2012, which pertains to the disqualification of beneficiaries who are involved in adultery or concubinage. Article 739 of the Civil Code, which outlines void donations between parties guilty of such acts, was also cited to support her position.
Court's Analysis on Concubinage
The court found it unnecessary to classify the relationship between Petronilo and Candelaria as a donation analogous to life insurance beneficiary relationships. It determined that since Candelaria was not aware of Petronilo's prior marriage, the disqualification under Article 739 does not apply. Thus, the court ruled that Candelaria could still be considered a valid beneficiary.
Distinction of Assets
The court identified that the benefits from the SSS do not form part of the conjugal property governed by marriage laws. Instead, they are derived from a special fund established by Congress to protect employees against risks such as death, disability, and sickness. The court highlighted that benefits accrued from the SSS are based on contributions from the employee, employer, and government, and thus should not be classified as property earned during Petronilo's lifetime.
Non-Transferability and Acquisition of Benefits
Moreover, the court stated that the benefits under the Social Security Act are not tran
...continue readingCase Syllabus (G.R. No. L-21642)
Case Overview
- This case involves an appeal from the resolution of the Social Security Commission which declared respondent Candelaria Davac as the rightful recipient of death benefits related to the death of Petronilo Davac.
- Petronilo Davac was a member of the Social Security System (SSS) and had designated Candelaria Davac as his beneficiary in SSS Form E-1 while married to her, creating a conflict with claims from his first wife, Lourdes Tuplano.
Background Facts
- Petronilo Davac became a member of the SSS on September 1, 1957, with SS I.D. No. 08-007137.
- He submitted SSS Form E-1 on November 21, 1957, designating Candelaria Davac as his beneficiary, indicating their relationship as "wife."
- Petronilo died on April 5, 1959, prompting both Candelaria and Lourdes to file claims for the death benefits.
- Petronilo had two marriages: the first with Lourdes Tuplano on August 29, 1946, and the second with Candelaria Davac on January 18, 1949, resulting in two children.
Issue Presented
- The primary question for determination was whether the Social Security Commission correctly awarded death benefits to Candelaria Davac despite her status as the second wife, amid conflicting claims from Lourdes Tuplano.
Relevant Legal Provisions
- Section 13, Republic Act No. 1161 (