Del Val v Del Val

Francisco Del Val v Andres Del Val

GR L-9374, digest by Gabe Ruaro
Feb. 16, 1915
Moreland, J.
Short Version:
Gregorio del Valle died, leaving behind, among other things, a life insurance policy with Andres
del Val as beneficiary. Andres then used the proceeds to redeem land. Francisco, his brother,
claimed that the proceeds formed part of the estate, and thus that the land was co-owned.
The SC ruled that in accordance with American law, the proceeds to a life insurance policy
belong to the beneficiary, not the estate. Thus, the funds belonged to Andres. However, as to the
redeemed land, the ownership thereof depended on Andres intent in redeeming it. If he meant
to do so for all co-heirs, they co-own it. If he meant to do so for himself, he owns it. To ascertain
this intent, the case was remanded.
Facts:
Francisco del Valle and his brother Andres were the only legal heirs of Gregorio Nacianceno del
Val, who died intestate.
The important part of the estate was a life insurance plan for P40,000, of which P18,365
was paid. Andres had claimed the P40,000 under the policy after Gregorios death. Andres then
used P18, 365 to redeem property which had been sold to 3 rd persons via pacto de retro sale.
Andres, at the time that Francisco filed a complaint against him, had most of Gregorios
personal property, including the remaining P21,635 of the life insurance proceeds. Thus,
Francisco filed a complaint for partition of all the property left by Gregorio. As to the unpaid
balance, Francisco prayed that Andres be made to account for it, and that the sum be divided
equally among them, along with other properties.
In response, Andres made a general denial, and claimed to be the owner of the redeemed
real estate and the P21,635. He thus made a counterclaim asking to be declared owner of the
real estate and the balance of the policy. The Trial Court dismissed both the complaint and the
counterclaim, on the substantive ground that the action was regarding real estate, which, at the
time, could not be subject of partition.
Hence this appeal.
Issues:
1. WON the partition should have been carried out. (Yes)
2. WON the life insurance belongs exclusively to Andres as his individual and separate
property. (Yes)
3. WON the redeemed property belongs to the heirs in common. (not ruled upon;remanded)
Ratio:
1. The Courts have jurisdiction to divide personal property as well as real property. Here,
however, no division of the property was made. Rather, the property was turned over to
the heirs in bulk. Thus, they are still co-owners. While the estate was closed, this has
nothing to do with partition. Thats the job of the probate court.
2. The proceeds of an insurance policy belong exclusively to the beneficiary and not to the
decedents estate. They are the separate and individual property of the beneficiary, and
not the heirs of the person whose life was insured. The contract of life insurance is a
special contract and the destinations of its proceeds are determined by special laws.
Thus, the proceeds belong to Andres.
3. Having used a portion thereof in repurchasing the real estate, the ownership of the land
depends on the intention of Andres. If he meant to redeem the land for the benefit of all

heirs, its co-owned. If he meant to do so for himself, its his property. But that is an issue
to be determined by the lower court.
Judgment set aside. Case remanded to lower court.