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BERNARDINA P. BARTOLOME v. SOCIAL SECURITY SYSTEM

FACTS:

John Colcol was employed as an electrician by Scanmar Maritime Services, Inc. On June 2, 2008, an accident occurred on board the vessel where John was working, resulting in his death the following day. At the time of his death, John was childless and unmarried. Petitioner, Bernardina P. Bartolome, John's biological mother, filed a claim for death benefits under Presidential Decree No. 626 with the Social Security System (SSS). However, the claim was denied by the SSS La Union office, stating that John was legally adopted by another person. The denial was appealed to the Employees' Compensation Commission (ECC), which affirmed the ruling of the SSS and dismissed the claim. The ECC held that petitioner can no longer be considered John's primary beneficiary since John was legally adopted by another person. Both the SSS and the ECC ruled that petitioner is not entitled to the death benefits sought under PD 626. Petitioner filed a Motion for Reconsideration, which was also denied by the ECC. Aggrieved, petitioner filed this appeal. The pivotal issue in the case is whether the biological parents of a legally adopted employee are considered secondary beneficiaries and entitled to receive benefits under the Employees' Compensation Program (ECP).

ISSUES:

  1. Whether the ECC's denial of the petitioner's claim for death benefits on the ground that it was not proven that the adoptive parent was deceased is in error.

  2. Whether the petitioner is entitled to the death benefits claim in view of the employee's work-related demise.

  3. Whether Rule XV of the Amended Rules on Employees' Compensation is consistent with Article 167 (j) of the Labor Code.

  4. Whether the interpretation of the phrase "dependent parents" in Rule XV is in accordance with the general acceptation of the term "relatives" in statutory construction.

  5. Whether Rule XV, Section l(c)(l) of the Amended Rules on Employees' Compensation violates the equal protection clause.

  6. Whether the phrase "illegitimate" as appearing in Rule XV, Section 1(c)(1) of the Amended Rules on Employees' Compensation is unconstitutional.

  7. Whether the biological parents of an adopted child retain their rights of succession to the estate of their child who was the subject of adoption.

  8. Whether the death of the adoptive parent restores the parental authority of the biological parent over the adopted child.

  9. Whether the petitioner, as the biological parent of the adoptee, is entitled to death benefit claims as a secondary beneficiary under PD 626 as a dependent parent.

RULING:

  1. The ECC's denial of the petitioner's claim for death benefits on the ground that it was not proven that the adoptive parent was deceased is in error. The ECC overlooked a crucial piece of evidence, namely the adoptive father's death certificate, which indicated that he has already passed away.

  2. The petitioner is entitled to the death benefits claim in view of the employee's work-related demise. The ECC's interpretation of the Amended Rules on Employees' Compensation, which deviates from the clear language of Article 167 (j) of the Labor Code, is contrary to law.

  3. Rule XV of the Amended Rules on Employees' Compensation is not consistent with Article 167 (j) of the Labor Code. The Court held that Rule XV, which interpreted the phrase "dependent parents" to refer to "legitimate parents," is a substantial deviation from the Labor Code. Any discrepancy between administrative regulations and the provisions of the law will always be resolved in favor of the basic law.

  4. The interpretation of the phrase "dependent parents" in Rule XV is not in accordance with the general acceptation of the term "relatives" in statutory construction. The Court cited previous jurisprudence in Diaz v. Intermediate Appellate Court, which held that the term "relatives" should be construed in its general and inclusive scope. The word "relatives" is a general term and should include not only collateral relatives but also all the kindred of the person spoken of, unless the context indicates a more restrictive or limited sense.

  5. Rule XV, Section l(c)(l) of the Amended Rules on Employees' Compensation violates the equal protection clause. The Court emphasized that equal protection requires that all persons or things similarly situated should be treated alike. While classification is permitted, it must pass the test of reasonableness. In this case, the rule that limits the claim of benefits to legitimate parents discriminates against illegitimate parents without a compelling reasonable basis.

  6. The Supreme Court ruled that the phrase "illegitimate" is unconstitutional. There is no justification for limiting secondary parent beneficiaries to the legitimate ones. The classification is not germane to the law being implemented and there is no pressing government concern or interest that requires protection so as to warrant balancing the rights of unmarried parents. The SSS can better fulfill its mandate if the provision is not so narrowly interpreted. Therefore, the phrase "illegitimate" is struck down as unconstitutional.

  7. Yes. The biological parents of an adopted child retain their rights of succession to the estate of their child who was the subject of adoption.

  8. Yes. The death of the adoptive parent restores the parental authority of the biological parent over the adopted child.

  9. Yes. The petitioner, as the biological parent of the adoptee, is entitled to death benefit claims as a secondary beneficiary under PD 626 as a dependent parent.

PRINCIPLES:

  • Findings of fact by administrative agencies are generally respected and accorded finality by courts. However, if there is crucial evidence overlooked by the agency, the court may disregard its findings. (General principle)

  • Laws are repealed only by subsequent ones, and their violation or non-observance shall not be excused by disuse, custom, or practice to the contrary. (Article 7, Civil Code of the Philippines)

  • Inconsistency between the Constitution and a law renders the latter void and the former governs.

  • Rule-making power should only be confined to details for regulating the mode or proceedings to carry into effect the law as enacted. It cannot amend or expand the statutory requirements.

  • Administrative or executive acts, orders, and regulations must always be in harmony with the provisions of the law. Any discrepancy will be resolved in favor of the basic law.

  • The term "relatives" in statutory construction should be understood to have a general and inclusive scope unless the context indicates a more restrictive or limited sense.

  • The equal protection clause requires equality among equals based on a valid classification that rests on substantial distinctions, is germane to the purpose of the law, is not limited to existing conditions only, and applies equally to all members of the same class. Superficial differences do not make for a valid classification.

  • The classification in a law or rule must be germane to the purpose of the law being implemented.

  • There must be a pressing government concern or interest that justifies the limitation of rights.

  • The best interest of the child is a paramount consideration in cases involving adoptees.

  • Restoration of parental authority and legal custody may be warranted in certain circumstances, such as the death of an adoptive parent when the adoptee is still a minor.

  • The ties between adoptees and their biological parents are not entirely eliminated even after adoption, as evidenced by certain rights of inheritance.

  • The biological parents retain their rights of succession to the estate of their child who was the subject of adoption.

  • The death of an adoptive parent restores the parental authority of the biological parent over the adopted child.

  • The designation of a beneficiary who is not related by blood to the member is allowed under RA 8282 (Social Security Law).