SSS v.

Candelaria
GR No. L-21642, July 30, 1966
Barrera, J.

FACTS
Petronilo was a member of the SSS and designated respondent Candelaria ,
identified as his wife, as his beneficiary. When he died, Candelaria and the other
respondent, Lourdes, Petronilo’s first wife, both filed a contradicting claim for death
benefits. The latter contends that the designation made in the person of the second
and therefore, bigamous wife is null and void because it deprives the lawful wife of
her share in the conjugal property.

The Social Security Commission declared Candelaria as the person entitled.

ISSUE
Whether SSS benefits are conjugal property

RULING
No. The court ruled that benefits accruing from membership in the SSS do not form
part of the properties of the conjugal partnership of the covered member. The
nature of the benefits partakes of a privilege secured by law. The amounts that may
thus be received cannot be considered property earned by the member during his
lifetime.

Futhermore, in the settlement of claims, the procedure to be observed is governed

not by the general provisions of law but by rules and regulations promulgated by
the Commission. Thus, if the money is payable to the estate of the deceased member,
it is the Commission, not the probate or regular court that determines the person/s
to whom it is payable. The benefits are not intended to form part of the estate of the
covered members.If there is a named beneficiary and the designation is not invalid,
it is not the heirs of the employee who are entitiled to receive the benefits.

ThusCandelaria is not guilty of concubinage, there being no proof that she had
knowledge of the previous marriage of her husband.