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DIGESTED - Melchora Cabanas

vs Francisco Pilapil

58 SCRA 94 Political Law Parens Patriae Strengthening the Family


Florentino Pilapil insured himself and he indicated in his insurance plan that his child will be
his beneficiary. He also indicated that if upon his death the child is still a minor; the
proceeds of his benefits shall be administered by his brother, Francisco Pilapil. The child
was only ten years of age when Florentino died and so Francisco then took charge of
Florentinos insurance proceeds for the benefit of the child.
On the other hand, the mother of the child Melchora Cabanas filed a complaint seeking the
delivery of the insurance proceeds in favor and for her to be declared as the childs trustee.
Francisco asserted the terms of the insurance policy and that as a private contract its terms
and obligations must be binding only to the parties and intended beneficiaries.
ISSUE: Whether or not the state may interfere by virtue of parens patriae to the terms of
the insurance policy.
HELD: Yes. The Constitution provides for the strengthening of the family as the basic social
unit, and that whenever any member thereof such as in the case at bar would be prejudiced
and his interest be affected then the judiciary if a litigation has been filed should resolve that
case according to the best interest of that person. The uncle here should not be the trustee,
it should be the mother as she was the immediate relative of the minor child and it is
assumed that the mother shall show more care towards the child than the uncle will. The
application ofparens patriae here is in consonance with this countrys tradition of favoring
conflicts in favor of the family hence preference to the parent (mother) is observed.