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SOCIAL SECURITY SYSTEM v. ROSANNA H. AGUAS

FACTS:

The petitioner in this case is Rosanna H. Aguas, the surviving spouse of Pablo Aguas who was a member of the Social Security System (SSS) and a pensioner. Pablo died on December 8, 1996, and Rosanna filed a claim with the SSS for death benefits, indicating that Pablo was survived by their minor child, Jeylnn. The SSS received a letter from Leticia Aguas-Macapinlac, the sister of Pablo, contesting Rosanna's claim and alleging that Rosanna had abandoned the family and had children with another man. Based on these allegations, the SSS suspended the payment of Rosanna and Jeylnn's monthly pension. The SSS conducted an investigation and concluded that Pablo had no legal children with Rosanna, and that Jeylnn and Jefren were Rosanna's children with Romeo. The SSS denied Rosanna's request to resume the pension and ordered her to refund the amount of P10,350.00 representing the death benefits released to her and Jeylnn. Rosanna and Jeylnn requested reconsideration but their request was denied. They then filed a claim/petition for the Restoration/Payment of Pensions with the Social Security Commission (SSC).

The SSC denied the claims of Rosanna, Janet, and Jeylnn, ruling that Rosanna was no longer entitled to support from Pablo prior to his death due to her act of adultery. The SSC also found that Jeylnn and Jenelyn were the same person and that she was the daughter of Rosanna and Romeo dela Peña. As for Janet, the SSC relied on the testimony of Leticia that Janet was only adopted by Pablo and Rosanna.

The claimants appealed to the Court of Appeals (CA), which reversed the SSC's decision and declared the claimants entitled to the SSS benefits. The CA relied on the birth certificates of Janet and Jeylnn as binding records that prove they were the children of the deceased. The CA also found no evidence to show that Rosanna ceased to receive support from Pablo before his death.

The SSS filed a petition before the Supreme Court, seeking a reversal of the CA's decision. The petitioner argues that Rosanna forfeited her right to be supported by her deceased husband, Pablo, when she engaged in an intimate and illicit relationship with Romeo dela Peña and married him while still married to Pablo. The petitioner claims that Rosanna's act of adultery is evident from the birth certificate of Jefren H. dela Peña, who was allegedly the child of Rosanna and Romeo dela Peña.

ISSUES:

  1. Whether Rosanna Aguas is actually dependent for support upon the member during his lifetime to qualify as a primary beneficiary within the intent of Section 8(e), in relation to Section 8(k) of the SSS Law, as amended.

  2. Whether Janet Aguas and Jeylnn Aguas are entitled to the pension benefit accruing from the death of Pablo Aguas.

  3. Whether Jeylnn is entitled to a monthly pension as a legitimate child of the deceased.

  4. Whether Rosanna is entitled to a monthly pension as the legitimate spouse of the deceased.

  5. Whether or not Rosanna Hernandez is entitled to the SSS death benefits accruing from the death of Pablo Aguas.

  6. Whether or not Jeylnn H. Aguas is the legitimate child of Pablo Aguas.

RULING:

  1. The petition is partly meritorious.

  2. The Court ruled that Jeylnn is entitled to a monthly pension as a legitimate child of the deceased. The Court found that Jeylnn's claim was supported by her birth certificate, which bears the signature of the deceased. The Court recognized the presumption of legitimacy under Article 164 of the Family Code, and since there was no proof that the deceased challenged Jeylnn's legitimacy during his lifetime, her status as a legitimate child of the deceased cannot be contested.

  3. The Court ruled that Janet is not entitled to a monthly pension as she failed to sufficiently prove her parentage and adoption. While Janet submitted a photocopy of her birth certificate, it was not verified by the civil register and therefore lacked probative weight. Additionally, the witnesses testified that Janet was not the real child but merely adopted by the deceased and his spouse. Without any proof of legal adoption, Janet cannot be considered a dependent child of the deceased.

  4. Rosanna Hernandez is not entitled to the SSS death benefits accruing from the death of Pablo Aguas because she failed to prove her dependency on him for support at the time of his death.

  5. Jeylnn H. Aguas is declared entitled to the SSS death benefits accruing from the death of Pablo Aguas as she has been established as his legitimate child.

PRINCIPLES:

  • The Court may review findings of fact when the judgment is based on a misapprehension of facts, when the findings of the appellate court are contrary to those of the trial court or quasi-judicial agency, or when the findings are premised on the absence of evidence and are contradicted by the evidence on record.

  • Substantial evidence, the quantum of evidence required to establish a fact in cases before administrative or quasi-judicial bodies, is that level of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion.

  • The presumption of legitimacy under Article 164 of the Family Code applies to children conceived or born during the marriage of the parents and becomes conclusive in the absence of proof to the contrary.

  • A birth certificate signed by the father is a competent evidence of paternity.

  • The presumption of legitimacy cannot extend to a child if their date of birth is not substantially proven.

  • Only "legally adopted" children are considered dependent children under the law.

  • For a spouse to qualify as a primary beneficiary, they must establish that they are the legitimate spouse dependent on the employee for support.

  • Dependency for support must be shown and cannot be presumed from the fact of marriage alone.

  • A person seeking to be declared a dependent beneficiary for purposes of receiving SSS death benefits must prove compliance with all statutory requirements, including the dependency on the deceased member for support at the time of his or her death.

  • In determining the legitimacy of a child for the purpose of SSS death benefits, the Court may consider baptismal certificates as evidence but will also take into account other relevant circumstances surrounding the child's birth and parentage.