G.R. No.

181132 June 5, 2009

MARAMAG V. MARAMAG

FACTS:

The case stems from a petition filed against respondents with the RTC for revocation and/or reduction of
insurance proceeds for being void and/or inofficious The petition alleged that! "#$ petitioners were the
legitimate wife and children of %oreto &aramag "%oreto$, while respondents were %oreto's illegitimate
famil() "2$ *va de +u,man &aramag "*va$ was a concubine of %oreto and a suspect in the -illing of the
latter, thus, she is dis.ualified to receive an( proceeds from his insurance policies from /nsular %ife
0ssurance Compan(, %td "/nsular$ and +reat 1acific %ife 0ssurance Corporation "+repalife$) "2$ the
illegitimate children of %oreto34dessa, 5arl 6rian, and Trisha 0ngelie3were entitled onl( to one7half
of the legitime of the legitimate children, thus, the proceeds released to 4dessa and those to be released to
5arl 6rian and Trisha 0ngelie were inofficious and should be reduced) and "8$ petitioners could not be
deprived of their legitimes, which should be satisfied first /n answer, /nsular admitted that Loreto
misrepresented Eva as is !e"itimate #i$e and %dessa& 'ar! (rian& and Trisa An"e!ie as is
!e"itimate )i!dren& and that the( filed their claims for the insurance proceeds of the insurance policies)
that when it ascertained that *va was not the legal wife of %oreto, it dis*+a!i$ied er as a ,ene$i)iar-
and divided te pro)eeds amon" %dessa& 'ar! (rian& and Trisa An"e!ie, as the remaining
designated beneficiaries) and that it released 4dessa's share as she was of age, but withheld the release of
the shares of minors 5arl 6rian and Trisha 0ngelie pending submission of letters of guardianship /nsular
alleged that the complaint or petition $ai!ed to state a )a+se o$ a)tion insofar as it sought to declare as
void the designation of *va as beneficiar() and insofar as it sought to declare as inofficious the shares of
4dessa, 5arl 6rian, and Trisha 0ngelie, )onsiderin" tat no sett!ement o$ Loreto.s estate ad ,een
$i!ed nor had the respective shares of the heirs been determined /ns+!ar $+rter )!aimed tat it #as
,o+nd to onor te ins+ran)e po!i)ies desi"natin" te )i!dren o$ Loreto #it Eva as ,ene$i)iaries
p+rs+ant to Se)tion 03 o$ te /ns+ran)e Code. /n its own answer, +repalife alleged that *va was not
designated as an insurance polic( beneficiar() that the claims filed b( 4dessa, 5arl 6rian, and Trisha
0ngelie were denied because %oreto was ineligible for insurance due to a misrepresentation in his
application form
1etitioners alleged that the issue raised b( /nsular and +repalife was purel( legal 9 whether the complaint
itself was proper or not 9 and that te desi"nation o$ a ,ene$i)iar- is an a)t o$ !i,era!it- or a donation
and, therefore, sub:ect to the provisions of 0rticles ;52 and ;;2 of the Civil Code /n repl(, both /nsular
and +repalife countered that te ins+ran)e pro)eeds ,e!on" e1)!+sive!- to te desi"nated ,ene$i)iaries
in te po!i)ies& not to te estate or to te eirs o$ te ins+red +repalife also reiterated that it had
dis.ualified *va as a beneficiar( when it ascertained that %oreto was legall( married to <icenta
1angilinan &aramag The trial court dismissed the case with respect to defendants 4dessa, 5arl 6rian
and Trisha &aramag The action shall proceed with respect to the other defendants *va <erna de
+u,man, /nsular %ife and +repalife The court ruled that the /nsurance Code, as amended, contains a
provision regarding to whom the insurance proceeds shall be paid /t is ver- )!ear +nder Se). 03 tereo$
tat te ins+ran)e pro)eeds sa!! ,e app!ied e1)!+sive!- to te proper interest o$ te person in
#ose name or $or #ose ,ene$it it is made, unless otherwise specified in the polic( =ince the
defendants are the ones named as the primar( beneficiar( in the insurances ta-en b( the deceased %oreto
and there is no showing that herein plaintiffs were also included as beneficiar( therein the insurance
proceeds shall e>clusivel( be paid to them This is because the beneficiar( has a vested right to the
indemnit(, unless the insured reserves the right to change the beneficiar( ?either could the plaintiffs
invo-ed the law on donations or the rules on testamentar( succession in order to defeat the right of herein
defendants to collect the insurance indemnit( Te ,ene$i)iar- in a )ontra)t o$ ins+ran)e is not te
donee spo2en in te !a# o$ donation. Te r+!es on testamentar- s+))ession )annot app!- ere& $or
te ins+ran)e indemnit- does not parta2e o$ a donation. 0s such, the insurance indemnit( cannot be
considered as an advance of the inheritance which can be sub:ect to collation The concubine, *va, is
forbidden from receiving an( donation under 0rticle ;29 and cannot be named beneficiar( of a life
insurance polic( of %oreto /f a concubine is made the beneficiar(, it is believed that the insurance
contract will still remain valid, but the indemnit( must go to the legal heirs and not to the concubine, for
evidentl(, what is prohibited under 0rt 20#2 is the naming of the improper beneficiar( /n such case, the
action for the declaration of nullit( ma( be brought b( the spouse of the donor or donee, and the guilt of
the donor and donee ma( be proved b( preponderance of evidence in the same action "Comment of
*dgardo % 1aras, Civil Code of the 1hilippines, page @9;$ =ince the designation of defendant *va
<erna de +u,man as one of the primar( beneficiar( in the insurances ta-en b( the late %oreto is void
under 0rt ;29 of the Civil Code, the insurance indemnit( that should be paid to her must go to the legal
heirs of the deceased which this court ma( properl( ta-e cogni,ance as the action for the declaration for
the nullit( of a void donation falls within the general :urisdiction of this Court 4n motion for
reconsideration, the trial court dismissed the case against *va since /nsular averred that the proceeds were
divided among the three children as the remaining named beneficiaries while +repalife, for its part, also
alleged that the premiums paid had alread( been refunded
/==A*! B/? the estate of the deceased %oreto has a right to claim the proceeds of the insurances paid to
the mistress, *va, and to the illegitimate children as named beneficiaries to the insurances
C*%D! ?one
A!to+" petitioners are te !e"itimate eirs o$ Loreto& te- #ere not named as ,ene$i)iaries in te
ins+ran)e po!i)ies issued b( /nsular and +repalife The basis of petitioners' claim is that *va, being a
concubine of %oreto and a suspect in his murder, is dis.ualified from being designated as beneficiar( of
the insurance policies, and that *va's children with %oreto, being illegitimate children, are entitled to a
lesser share of the proceeds of the policies /t is evident from the face of the complaint that petitioners are
not entitled to a favorable :udgment in light of 0rticle 20## of the Civil Code which e>pressl( provides
that insurance contracts shall be governed b( special laws, i.e., the /nsurance Code Se)tion 03 o$ te
/ns+ran)e Code states3

SECTION 53. The insurance proceeds shall be applied exclusively to the proper
interest of the person in whose nae or for whose benefit it is ade unless otherwise
specified in the policy.

1ursuant thereto, it is obvious that the onl( persons entitled to claim the insurance proceeds are either the
insured, if still alive) or the beneficiar(, if the insured is alread( deceased, upon the maturation of the
polic( The e>ception to this rule is a situation where the insurance contract was intended to benefit third
persons who are not parties to the same in the form of favorable stipulations or indemnit( /n such a case,
third parties ma( directl( sue and claim from the insurer 3etitioners are tird parties to te ins+ran)e
)ontra)ts with /nsular and +repalife and, thus, are not entitled to the proceeds thereof 0ccordingl(,
respondents /nsular and +repalife have no legal obligation to turn over the insurance proceeds to
petitioners Te revo)ation o$ Eva as a ,ene$i)iar- in one po!i)- and er dis*+a!i$i)ation as s+) in
anoter are o$ no moment )onsiderin" tat te desi"nation o$ te i!!e"itimate )i!dren as
,ene$i)iaries in Loreto.s ins+ran)e po!i)ies remains va!id. (e)a+se no !e"a! pros)ription e1ists in
namin" as ,ene$i)iaries te )i!dren o$ i!!i)it re!ationsips ,- te ins+red, the shares of *va in the
insurance proceeds, whether forfeited b( the court in view of the prohibition on donations under 0rticle
;29 of the Civil Code or b( the insurers themselves for reasons based on the insurance contracts, must be
awarded to the said illegitimate children, the designated beneficiaries, to the e>clusion of petitioners /t is
on!- in )ases #ere te ins+red as not desi"nated an- ,ene$i)iar-& or #en te desi"nated
,ene$i)iar- is dis*+a!i$ied ,- !a# to re)eive te pro)eeds& tat te ins+ran)e po!i)- pro)eeds sa!!
redo+nd to te ,ene$it o$ te estate o$ te ins+red