Heirs of Maramag vs.

Maramag

G.R. No. 181132

June 5, 2009

Ponente: NACHURA, J.:

Nature of the Case: Petition for review on certiorari under Rule 45

Case Brief: This case seeks to reverse and set aside the Resolution of the Court of Appeals (CA),
dismissing petitioners appeal for lack of jurisdiction.

The case stems from a petition filed against respondents with the Regional Trial Court, Branch 29,
for revocation and/or reduction of insurance proceeds for being void and/or inofficious, with
prayer for a temporary restraining order (TRO) and a writ of preliminary injunction.

Facts: 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 ascertained that Eva was not the legal wife of Loreto, it disqualified
her as a beneficiary 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.

The petitioners 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) and Great Pacific Life Assurance Corporation (Grepalife); (3) the
illegitimate children of Loreto Odessa, Karl Brian, and Trisha Angelie were 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.

Issue:

Action of the Court: DENIED

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

Pursuant thereto, it is obvious that the only persons entitled to claim the insurance proceeds are
either the insured, if still alive; or the beneficiary, if the insured is already deceased, upon the
maturation of the policy. The exception 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 indemnity. In such a case, third parties may directly sue and claim from the insurer.

Petitioners are third parties to the insurance contracts with Insular and Grepalife and, thus, are not
entitled to the proceeds thereof. Accordingly, respondents Insular and Grepalife have no legal
obligation to turn over the insurance proceeds to petitioners. The revocation of Eva as a beneficiary
in one policy and her disqualification as such in another are of no moment considering that the
designation of the illegitimate children as beneficiaries in Loretos insurance policies remains valid.
Because no legal proscription exists in naming as beneficiaries the children of illicit relationships
by the insured, the shares of Eva in the insurance proceeds, whether forfeited by the court in view
of the prohibition on donations under Article 739 of the Civil Code or by the insurers themselves
for reasons based on the insurance contracts, must be awarded to the said illegitimate children, the
designated beneficiaries, to the exclusion of petitioners. It is only in cases where the insured has
not designated any beneficiary, or when the designated beneficiary is disqualified by law to receive
the proceeds, that the insurance policy proceeds shall redound to the benefit of the estate of the
insured.

Ruling of the Case: In this regard, the assailed June 16, 2005 Resolution of the trial court should
be upheld. In the same light, the Decision of the CA dated January 8, 2008 should be sustained.
Indeed, the appellate court had no jurisdiction to take cognizance of the appeal; the issue of failure
to state a cause of action is a question of law and not of fact, there being no findings of fact in the
first place.