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HEIRS OF LORETO C. MARAMAG v. EVA VERNA DE GUZMAN MARAMAG

FACTS:

This is a petition for review on certiorari filed by the petitioners seeking to reverse and set aside the Court of Appeals' (CA) resolution dismissing their appeal for lack of jurisdiction. The case originated from a petition filed against the respondents with the Regional Trial Court (RTC) for the revocation and/or reduction of insurance proceeds from Insular Life Assurance Company, Ltd. (Insular) and Great Pacific Life Assurance Corporation (Grepalife). The petition alleged that the petitioners were the legitimate wife and children of Loreto Maramag, while the respondents were Loreto's illegitimate family. It further claimed that one of the respondents, Eva de Guzman Maramag, was a concubine of the deceased and a suspect in his killing, thus disqualified from receiving any insurance proceeds. The petitioners also argued that the shares of the illegitimate children should be reduced as they were inofficious. In their pleadings, Insular admitted Loreto's misrepresentation and disqualified Eva as a beneficiary, while Grepalife argued that Loreto was ineligible for insurance due to misrepresentation in his application form. The trial court declared the illegitimate family of Loreto in default and resolved that the action could proceed against the remaining defendants.

ISSUES:

  1. Whether the trial court erred in considering matters not alleged in the complaint, particularly the defenses raised by the defendants in their answers, in determining the merits of a motion to dismiss for failure to state a cause of action.

  2. Whether the Regional Trial Court engaged in the examination and determination of facts and their probative value in granting a motion for reconsideration of a motion to dismiss for failure to state a cause of action.

  3. Whether the members of the legitimate family are entitled to the proceeds of the insurance policies designated for the concubine and/or the illegitimate children.

RULING:

  1. The Supreme Court ruled that while the general rule is that the sufficiency of a cause of action should be based only on the allegations of the complaint, there are recognized exceptions where the veracity of the allegations isn't hypothetically admitted. These exceptions applied in the case.

  2. The Supreme Court upheld the trial court's ruling, finding that the determination that the complaint failed to state a cause of action could consider the disqualification or revocation of Eva as a beneficiary as alleged by the defendants in their answers.

  3. The Supreme Court held that the legitimate heirs do not have a legal right to claim the insurance proceeds as the proceeds are governed by the provisions of the Insurance Code which states that the proceeds are exclusively applied to the proper interest of the named beneficiaries. Consequently, the illegitimate children of Loreto are the proper beneficiaries under the insurance policies.

PRINCIPLES:

  1. Contract of Insurance Governed by Special Laws - Articles 2011 and 2012 of the Civil Code state that insurance contracts are governed by special laws, primarily the Insurance Code.

  2. Sufficiency of Cause of Action - The determination of whether a complaint states a cause of action should generally be based on the allegations in the complaint, but exceptions exist where the veracity of allegations isn't hypothetically admitted.

  3. Right of Designated Beneficiary - Under Section 53 of the Insurance Code, insurance proceeds are applied exclusively to the proper interest of the designated beneficiary unless otherwise specified in the policy.

  4. Designation of Beneficiaries - The naming of beneficiaries, including illegitimate children, in insurance policies, is generally valid, unless otherwise prohibited by law (e.g., Article 739 of the Civil Code regarding concubines).

  5. Effect of Disqualification of a Beneficiary - If a named beneficiary (e.g. a concubine) is disqualified, their share could be awarded to the other named beneficiaries and not to the estate of the insured, unless the policy explicitly includes provision to that effect.

  6. Question of Law vs. Question of Fact - The issue of whether a complaint states a cause of action constitutes a question of law, not of fact, suitable for resolution without delving into factual determinations.