Social Security System vs. Candelaria D. Davac, Et Al. G.R. No. L-21642, July 30, 1966 Facts

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Deocaris, Nicole Anne C. Social Security Act of 2008 (RA No.

11199)
Agrarian Law and Social Legislation/ 2E Sec. 13 of RA No. 1161
Case Digest SSS vs. Davac

SOCIAL SECURITY SYSTEM vs. CANDELARIA D. DAVAC, ET AL.


G.R. No. L-21642, July 30, 1966
FACTS:
The facts of the case as found by the Social Security Commission, briefly are: The late Petronilo
Davac, a former employee of Lianga Bay Logging Co., Inc. became a member of the Social
Security System (SSS for short). He designated respondent Candelaria Davac as his
beneficiary and indicated his relationship to her as that of "wife". He died on April 5, 1959 and,
thereupon, each of the respondents (Candelaria Davac and Lourdes Tuplano) filed their claims
for death benefit with the SSS. It appears from their respective claims and the documents
submitted in support thereof, that the deceased contracted two marriages, the first, with
claimant Lourdes Tuplano who bore him a child, Romeo Davac, and the second, with
Candelaria Davac with whom he had a minor daughter Elizabeth Davac. Due to their conflicting
claims, the processing thereof was held in abeyance, whereupon the SSS filed this petition
praying that respondents be required to interpose and litigate between themselves their
conflicting claims over the death benefits in question.
ISSUE:
Whether or not the Social Security Commission acted correctly in declaring respondent
Candelaria Davac as the person entitled to receive the death benefits in question.
RULING:
Yes, without deciding whether the naming of a beneficiary of the benefits accruing from
membership in the Social Security System is a donation, or that it creates a situation analogous
to the relation of an insured and the beneficiary under a life insurance policy, it is enough, for
the purpose of the instant case, to state that the disqualification is not applicable to herein
appellee Candelaria Davac because she was not guilty of concubinage, there being no proof
that she had knowledge of the previous marriage of her husband Petronilo.
Regarding the second point raised by appellant, the benefits accruing from membership in the
Social Security System do not form part of the properties of the conjugal partnership of the
covered member. The benefits receivable under the Act is in the nature of a special privilege or
an arrangement secured by the law, pursuant to the policy of the State to provide social security
to the workingmen. The amounts that may thus be received cannot be considered as property
earned by the member during his lifetime. His contribution to the fund, it may be noted,
constitutes only an insignificant portion thereof. Then, the benefits are specifically declared not
transferable, and exempted from tax legal processes, and lien. Furthermore, in the settlement of
claims thereunder the procedure to be observed is governed not by the general provisions of
law, but by rules and regulations promulgated by the Commission. Thus, if the money is payable
to the estate of a deceased member, it is the Commission, not the probate or regular court that
determines the person or persons to whom it is payable. The benefits under the Social Security
Act are not intended by the lawmaking body to form part of the estate of the covered members.
In short, if there is a named beneficiary and the designation is not invalid (as it is not so in this
case), it is not the heirs of the employee who are entitled to receive the benefits (unless they are
the designated beneficiaries themselves). It is only when there are no designated beneficiaries
or when the designation is void, that the laws of succession are applicable. And we have
already held that the Social Security Act is not a law of succession.
DISPOSITION:
Wherefore, in view of the foregoing considerations, the resolution of the Social Security
Commission appealed from is hereby affirmed, with costs against the appellant.

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