Case Summary (G.R. No. L-21587)
Factual Background and Procedural History
Clemente Bailon married Alice Diaz in 1955 in Barcelona, Sorsogon. In 1970, Bailon petitioned the Court of First Instance (CFI) of Sorsogon to declare Alice presumptively dead. The CFI granted the petition by order dated December 10, 1970. In 1983, Bailon married Teresita Jarque. Bailon died in 1998 as an SSS member and retiree. Teresita Jarque filed claims for funeral and death benefits with the SSS and was initially granted those benefits. Cecilia Bailon-Yap, claiming to be Bailon’s daughter by Elisa Jayona, contested the payments, asserting Bailon had three valid marriages simultaneously and that Teresita’s documents were fraudulent.
Dispute on the Validity of Marriages and Beneficiary Claims
Cecilia and her siblings, along with Elisa Jayona, filed claims as legitimate beneficiaries and contested the payments to Teresita. The SSS Legal Unit recommended cancellation of payments to Teresita, claiming the first marriage was never legally dissolved since Alice had not disappeared but was still living. The SSS asserted that Bailon was the abandoning spouse and that his subsequent marriage to Teresita was void for bigamy, based on the absence of a valid order terminating the first marriage.
Findings and Rationale of the Social Security Commission (SSC)
The SSC ruled that Teresita’s marriage to Bailon was void since the declaration of presumptive death of Alice was obtained through fraud and did not become final. The SSC determined Alice had never left Barcelona and Bailon did not provide sufficient proof of her absence. Consequently, Teresita was deemed only a common-law wife and not entitled to SSS death benefits. The SSC ordered Teresita to refund the funeral and death benefits previously paid to her and instructed the SSS to pay Alice the appropriate benefits.
Appeal to the Court of Appeals (CA) and Its Decision
The respondent, Teresita Jarque, appealed the SSC decision to the CA. The CA reversed the SSC ruling on the grounds that although the presumption of death is a "presumption juris tantum" and thus not absolute, only a competent court can annul or declare a subsequent marriage void. The CA held that the SSC had no authority to review or invalidate the CFI’s order declaring Alice presumptively dead or to declare the second marriage void. The CA emphasized the due process issues, noting Teresita was not given ample opportunity to present evidence during the SSC proceedings. It ruled that Teresita’s marriage remained valid until annulled by judicial action or termination by affidavit of reappearance and ordered the SSS to pay all benefits due to her.
Petition for Review before the Supreme Court (SC) and Issues Raised
The SSS filed a petition for review on certiorari, contending that the CA erred by disregarding the SSC’s factual findings that established the prior and subsisting marriage between Bailon and Alice and that the subsequent marriage to Teresita was void. The SSS argued the CA ignored the SSC’s authority under Section 5 of the Social Security Law to determine rightful beneficiaries and violated due process protections.
Applicable Law and Legal Analysis
The SC applied the 1987 Philippine Constitution and relevant laws governing marriage and social security benefits. The Civil Code provisions on bigamous marriage (Art. 83) were methodically examined. It was emphasized that a subsequent marriage contracted during the subsistence of a first marriage is void unless the former was annulled, dissolved, or the first spouse had been absent for seven consecutive years and presumed dead (juris tantum presumption). Importantly, even under these exceptions, the subsequent marriage remains valid "until declared null and void by a competent court."
The SC cited Arturo M. Tolentino’s commentaries detailing the burden of proof in annulment cases and explained that the second marriage is voidable, not void ab initio, and can only be terminated either by affidavit of reappearance of the absentee spouse or a judicial annulment during the lifetime of either spouse. Upon death of either spouse, actions for annulment terminate, and the marriage is considered valid for all legal intents.
Supreme Court’s Conclusion and Holding
The SC ruled that the SSC exceeded its authority by invalidating the CFI’s order and by effectively annulling the second marriage, an act reserved to judicial courts. The SSC’s disregard of court orders and substitution of its own factual findings amounted to an unlawful act beyond its jurisdiction. The presumption of death and the subsequent marriage remained valid until judicially annulled. Since no
Case Syllabus (G.R. No. L-21587)
Parties and Case Background
- Petitioner: Social Security System (SSS), represented by its Social Security Commission (SSC).
- Respondent: Teresita Jarque Vda. de Bailon, claimant to SSS death and funeral benefits as alleged surviving spouse of deceased Clemente G. Bailon.
- The case arose from conflicting claims over the entitlement to death benefits following the demise of Clemente G. Bailon, an SSS retiree pensioner who died January 30, 1998.
- The dispute concerned the validity of respondent's marriage to Bailon, in light of Bailon’s prior marriage to Alice P. Diaz, who was declared presumptively dead by judicial order.
Factual History and Chronology
- April 25, 1955: Clemente G. Bailon married Alice P. Diaz in Barcelona, Sorsogon.
- October 9, 1970: Bailon petitioned before the Court of First Instance (CFI) of Sorsogon to declare Alice presumptively dead after more than 15 years of absence.
- December 10, 1970: CFI granted the petition declaring Alice presumptively dead for all legal intents except succession.
- August 8, 1983: Bailon contracted a second marriage with respondent Teresita Jarque in Casiguran, Sorsogon.
- January 30, 1998: Bailon died, triggering claims for SSS funeral and death benefits.
- Respondent received funeral benefits (P12,000) and death benefits, later contested by Cecilia Bailon-Yap, a daughter of Bailon and Elisa Jayona, claiming Bailon had three concurrent marriages, including one to Elisa, all alive.
- Multiple affidavits and claims were filed contesting respondent’s legitimacy as Bailon’s lawful spouse and thus rightful beneficiary.
Issues Presented
- Whether the Social Security Commission (SSC) and SSS had authority to invalidate the prior CFI order declaring Alice Diaz presumptively dead and to declare respondent’s marriage to Bailon void for bigamy.
- Whether respondent Teresita Jarque is the legitimate surviving spouse and primary beneficiary entitled to SSS death and funeral benefits.
- Whether the cancellation of respondent’s claims and orders to refund payments were proper.
- Whether SSS and SSC acted with due process and within jurisdiction when reevaluating and overturning court decisions regarding the presumption of death and marital status.
- The application and interpretation of Civil Code Articles on subsequent marriages during subsistence of prior marriage, and the effect of the presumed death declaration.
Parties’ Contentions
Social Security System’s Contentions
- The SSC found that the first wife, Alice Diaz, never disappeared, asserting the CFI order of presumptive death was invalid and procured by fraud.
- Consequently, Bailon’s second marriage to respondent was bigamous and void from inception.
- The SSS recommended cancellation of respondent’s death pension benefits and refund of amounts already paid.
- They argued that only Alice Diaz, being the legitimate spouse, was entitled to death benefits.
- The SSC declared respondent’s status as a common-law wife without legitimate claim to benefits.
- Maintained that it had power to determine beneficiary status and to overturn court decrees based on its investigations.
Respondent Teresita Jarque’s Contentions
- Respondent asserted her marriage with Bailon was not declared null or void by any court.
- Claimed she remained Bailon's legitimate spouse as per marriage contract and designation as beneficiary.
- Protested the cancellation of benefits and the demand for refund alleging lack of substantial evidence and due process.
- Argued that SSS and SSC had no authority to question or review final judicial declarations, including the presumptive death order.
- Emphasized that no co