CABANAS vs.

PILAPIL
58 SCRA 94

Facts: Pilapil insured himself and he indicated in his insurance plan that his child will be his
beneficiary. He also indicated that if upon his death the child is still a minor; the proceeds of his
benefits shall be administered by his brother, Francisco Pilapil. The child was only ten years of
age when Florentino died and so Francisco then took charge of Florentinos insurance proceeds
for the benefit of the child.

On the other hand, the mother of the child Melchora Cabanas filed a complaint seeking the
delivery of the insurance proceeds in favor and for her to be declared as the childs trustee.
Francisco asserted the terms of the insurance policy and that as a private contract its terms and
obligations must be binding only to the parties and intended beneficiaries.

Issue: Whether or not the state may interfere by virtue of parens patriae to the terms of the
insurance policy.

Held: Yes. The Constitution provides for the strengthening of the family as the basic social unit,
and that whenever any member thereof such as in the case at bar would be prejudiced and his
interest be affected then the judiciary if a litigation has been filed should resolve that case
according to the best interest of that person. The uncle here should not be the trustee, it should
be the mother as she was the immediate relative of the minor child and it is assumed that the
mother shall show more care towards the child than the uncle will. The application of parens
patriae here is in consonance with this countrys tradition of favoring conflicts in favor of the
family hence preference to the parent (mother) is observed.