Ramos, Dianne Nicole L.

Claim of Death Benefits

Agrarian Law and Social Legislation / 2C SSS Law
Case Digest Tecson v. SSS
---------------------------------------------------------------------------------------------------------------------------

TECSON v. SSC
G.R. No. L-15798, 28 December 1961

FACTS:

When Lim Hoc, an employee of Yuyitung Publishing Company died, his friend and co-worker,
Jose P. Tecson, filed for a claim of death benefits. This is because in Lim Hoc’s SSS Form E-1,
Tecson was designated Tecson as his beneficiary.

The SSS denied Tecon’s petition, stating that the SSS death benefits is meant to grant and
afford protection to the covered employee, as well as his family, not just anyone that the
employee designates.

ISSUE:

Whether or not Tecson can claim Lim Hoc’s death benefits.

RULING:

Yes. The law is clear and explicit that in the absence of primary beneficiaries, as in this case,
those whom the SSS member designates as his beneficiary should be the one to benefit from
his contributions. In the case at bar, Lim Hoc did not state in his SSS that he has a wife and
children in China because at that time, they were not dependent on him. This might also be due
to lack of communication between China and the Philippines or simply the express desire of Lim
Hoc to give the benefits to Jose Tecson. Whatever, the case may be, the fact that Lim Hoc had
designated Tecson as a beneficiary would make him the one to benefit from Lim Hoc’s
contributions.

Furthermore, the SSS is not a law of succession. It is only in the absence of primary and
secondary beneficiaries that it becomes one. The following persons may be designated as
beneficiaries entitled to receive death benefits provided they have been registered as such in
the records of the System prior to said employee's death, to wit:
(1) The legitimate widow or widower if not legally separated from the deceased; 
(2) Legitimate and/or legitimated children; 
(3) Grandchildren;
(4) Parents; 
(5) Grandparents;
(6) Natural children duly acknowledged;
(7) Brothers and/or sisters;
(8) In the absence of any of the foregoing relatives, any other person designated by the
employee. (Rule 7, [3], of the Rules and Regulations of the Social Security System).

As stated, there are no relatives recorded by Lim Hoc in his SSS and therefore, the person
whom he designates as his beneficiary shall be the one to receive his death benefits.

1
 Ramos, Dianne Nicole L. Claim of Death Benefits
Agrarian Law and Social Legislation / 2C SSS Law
Case Digest Tecson v. SSS
---------------------------------------------------------------------------------------------------------------------------

DISPOSITION:

FOR ALL THE FOREGOING CONSIDERATIONS, the resolution should be, as it is hereby,
set aside and annulled, and the respondent System is hereby ordered to pay the
monetary claim of Jose P. Tecson. Without costs.