Souther Luzon Employee’s Association v. Golpeo - Insurance Beneficiaries
96 PHIL 83
> SLEA is composed of laborers and employees of the LTBC and BTC (now BLTB Co.), and one of its purposes is mutual aid of its members and their dependents in case of death.
> Roman Concepcion was a member until his death in 1950.
> In 1949, SLEA adopted a resolution providing that: A member may, if he chooses, put down his common law wife and/or children he had with her as his beneficiaries; and such person so named by the member will be the sole persons to be recognized by SLEA regarding claims for condolence contributions.
> Roman listed as his beneficiaries Aquilina Maloles and their 4 children. After his death, SLEA was able to collect voluntary contribution from its members amounting to P2,205.
> Three sets of claimants to the amount presented themselves to the association namely:
o Juanita Golpeo, legal wife, and her children
o Aquilina Maloles, the common law wife, and her children
o Elsie Hicban, another common law wife of Roman, and her child.
> SLEA then filed an action for interpleader against the 3 conflicting claimants.
> Trial court rendered a decision declaring Maloles and her children the sole beneficiaries of the amount citing Del Val v. Del Val.
> Only Golpeo appealed. She argues that:
> The insurance code does not apply since the association is not an insurance company but a mutual benefit association.
> The stipulation between SLEA and Roman was void for being contrary to law, public morals and public policy, pursuant to Art. 739 of the CC ( donations between persons guilty of concubinage at the time of donation are void)
Whether or not Golpeo, the legal wife is entitled to the amount.
First of all, the lower court did not consider the association as a regular insurance company, but merely ruled that the death benefit in question is analogous to insurance. Besides, even the Administrative Code describes a mutual benefit company as one which provides any method of life insurance among its members out of dues or assessments collected from its membership.
Secondly, without considering the intimation in the brief for Maloles that Golpeo, by her silence and actions had acquiesced in the illicit relations between her husband and Maloles, Golpeo’s argument would certainly NOT apply to the children of Maloles likewise named beneficiaries by the deceased. As a matter of fact, the NCC recognizes certain successional rights of illegitimate children.