Ramos, Dianne Nicole L.

Claim for Death Benefits

Agrarian Law and Social Legislation / 2C SSS Law
Case Digest SSS v. Davac
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SOCIAL SECUTIRY SYSTEM v. CANDELARIA D. DAVAC

G.R. No. L-21642, 30 July 1966

FACTS:

Petronilo Davas, a former employee of Linga Bay Logging Co. designated Candelaria Davac ias
his beneficiary, as his wife. Hence, upon his death, Candelaria filed for claim of death beenfits.
However, a few months later, Lourdes Tuplano file for a claim of death benefits as well. It
appears that Petronilo had contracted two marriages, both of which, bearing a child. The SSC
ruled in favor of Candelaria. Hence, Lourdes filed for an appeal. According to her, the marriage
between Candelaria is null and void and according to Article 739 of the Civil Code, the latter is
not entitled to receive donations from Petronilo. Also, she stated that she, being the wife, is the
one entitled to the benefits because it is a part of their conjugal property.

ISSUE:

Whether or not the SSC erred in declaring Candelaria as the one entitled to receive the death
benefits.

RULING:

No. The law stated that the beneficiaries, as recorded by his employer, should be entitled to the
benefits. The Court stated that Article 197 does not apply because it disqualifies concubines
from receiving donations. However, there is no proof that Candelaria had knowledge of
Petronilo’s previous marriage. Also, the benefits are not part of the conjugal property as it is
disbursed from public special fund created by Congress, to which each person’s contribution is
very small. It is not considered as one’s “property earned in his lifetime”.

Furthermore, it is the SSC which determines the persons whom the benefits is payable, not the
courts. Lastly, it is only when there are no designated beneficiaries or when the designation is
void, that the laws of succession are applicable.

DISPOSITION:

Wherefore, in view of the foregoing considerations, the resolution of the Social Security
Commission appealed from is hereby affirmed, with costs against the appellant.