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HEIRS OF MARAMAG

V
MARAMAG
FACTS

The case stems from a petition filed against respondents with the
Regional Trial Cour t, Branch 29, for revocation and/or reduction of
insurance proceeds for being void and/or inof ficious, with prayer for
a temporar y restraining order (TRO) and a writ of preliminar y
injunction.
The petition alleged that:
(1) petitioners were the legitimate wife and children of Loreto Maramag
(Loreto), while respondents were Loretos illegitimate family;
(2) Eva de Guzman Maramag (Eva) was a concubine of Loreto and a suspect
in the killing of the latter, thus, she is disqualified to receive any proceeds
from his insurance policies from Insular Life Assurance Company, Ltd.
(Insular)[4] and Great Pacific Life Assurance Corporation ( Grepalife);
(3) the illegitimate children of Loreto Odessa, Karl Brian, and Trisha
Angeliewere entitled only to one-half of the legitime of the legitimate
children, thus, the proceeds released to Odessa and those to be released to
Karl Brian and Trisha Angelie were inofficious and should be reduced; and
(4) petitioners could not be deprived of their legitimes, which should be
satisfied first.
Insular Life - admitted that Loreto misrepresented Eva as his legitimate
wife and Odessa, Karl Brian, and Trisha Angelie as his legitimate
children, and that they filed their claims for the insurance proceeds of
the insurance policies; that when it ascer tained that Eva was not the
legal wife of Loreto, it disqualified her as a beneficiar y and divided the
proceeds among Odessa, Karl Brian, and Trisha Angelie, as the
remaining designated beneficiaries; and that it released Odessas share
as she was of age, but withheld the release of the shares of minors
Karl Brian and Trisha Angelie pending submission of letters of
guardianship.

Grepalife (compulsar y counterclaim) alleged that Eva was not


designated as an insurance policy beneficiar y; that the claims filed by
Odessa, Karl Brian, and Trisha Angelie were denied because Loreto was
ineligible for insurance due to a misrepresentation in his application
form that he was born on December 10, 1936 and, thus, not more than
65 year s old when he signed it in September 2001; that the case was
premature, there being no claim filed by the legitimate family of
Loreto; and that the law on succession does not apply where the
designation of insurance beneficiaries is clear.
In their comment, petitioners alleged that the issue raised by
Insular and Grepalife was purely legal whether the complaint
itself was proper or not and that the designation of a beneficiary
is an act of liberality or a donation and, therefore, subject to the
provisions of Articles 752and 772 of the Civil Code.
In reply, both Insular and Grepalife countered that the insurance
proceeds belong exclusively to the designated beneficiaries in
the policies, not to the estate or to the heirs of the insured.

Ruling of the RTC: Motion to dismiss incorporated in the answer


of the defendants is granted

Ruling of the CA: dismissed the appeal for lack of jurisdiction


ISSUE

Are the members of the legitimate family entitled to the


proceeds of the insurance for the concubine?
RULING OF THE SUPREME COURT

No. Petition denied.

In this case, it is clear from the petition filed before the trial cour t that,
although petitioner s are the legitimate heir s of Loreto, they were not
named as beneficiaries in the insurance policies issued by Insular and
Grepalife .

The basis of petitioner s claim is that Eva, being a concubine of Loreto and
a suspect in his murder, is disqualified from being designated as
beneficiar y of the insurance policies, and that Evas children with Loreto,
being illegitimate children, are entitled to a lesser share of the proceeds of
the policies. They also argued that pur suant to Section 1 2 of the Insurance
Code, Evas share in the proceeds should be for feited in their favor, the
former having brought about the death of Loreto. Thus, they prayed that
the share of Eva and por tions of the shares of Loretos illegitimate children
should be awarded to them, being the legitimate heir s of Loreto entitled to
their respective legitimes.

It is evident from the face of the complaint that petitioner s are not entitled
to a favorable judgment in light of Ar ticle 2011 of the Civil Code which
expressly provides that insurance contracts shall be governed by special
laws, i.e., the Insurance Code. Section 53 of the Insurance Code states
S E C T I ON 5 3 . T h e i n s u r a n c e p r o c ee d s s h a l l b e a p p l i e d ex c l us i v el y to t h e p r o p e r
i n te r e s t o f t h e p e r s o n i n w h o s e n a m e o r f o r w h o s e b e n e f i t i t i s m a d e u n l e s s
o t h e r w is e s p e c i fi e d i n t h e p o l i c y .

Pet i t i o n e r s a r e t h i r d p a r t i e s to t h e i n s u r a n c e c o n t r a c t s w i t h I n s u l a r a n d G r e p a l i fe
a n d , t h u s , a r e n o t e n t i t l e d to t h e p r o c e e d s t h e r e o f . A c c o r d i n g l y, r e s p o n d e n t s I n s u l a r
a n d G r e p a l i fe h av e n o l e g a l o b l i g a t io n to t u r n o v e r t h e i n s u r a n c e p r o c e e d s to
p et i t i on e r s .

T h e r ev o c a t i o n o f E v a a s a b e n e f i c i a r y i n o n e p o l i c y a n d h e r d i s q ual i fi c a t io n a s s u c h
i n a n o t h e r a r e o f n o m o m en t c o n s i d e r i n g t h a t t h e d e s i g n a t i o n o f t h e i l l e g i t i ma te
c h i l d r e n a s b e n e f i c i a r ie s i n L o r eto s i n s u r a nc e p o l i c i es r e m a i n s v a l i d . B e c a u s e n o
l e g a l p r o s c r i p t i o n ex i s t s i n n a m i n g a s b e n e f i c i a r ie s t h e c h i l d r e n o f i l l i ci t
r e l a t i o n s h i p s b y t h e i n s u r e d , t h e s h a r e s o f E v a i n t h e i n s u r a n c e p r o c e e d s , w h et h e r
f o r fe i te d b y t h e c o u r t i n v i ew o f t h e p r o h i b i t io n o n d o n a t i o n s u n d e r A r t i c l e 7 3 9 o f
t h e C i v i l C o d e o r b y t h e i n s u r e r s t h e m s e l ve s f o r r e a s o n s b a s e d o n t h e i n s u r a n c e
c o n t r ac t s , m u s t b e aw a r d ed to t h e s a i d i l l e g i t im a te c h i l d r e n , t h e d e s i g n a te d
b e n e f i c ia r i e s , to t h e ex c l us i o n o f p et i t i o n e r s .

I t i s o n l y i n c a s e s w h e r e t h e i n s u r e d h a s n o t d e s i g n a te d a ny b e n e f i c ia r y, o r w h e n
t h e d e s i g n a te d b e n e f i c i a r y i s d i s q ua l i fi ed b y l aw to r e c e i ve t h e p r o c e ed s , t h a t t h e
i n s u r a n c e p o l i c y p r o c e e d s s h a l l r e d o un d to t h e b e n e f i t o f t h e e s t a te o f t h e i n s u r e d .