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    Topic: Beneficiaries (Life Insurance) - Statutory Limitations

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    Anonymous hS0s2mo
    The Supreme Court ruled that the proceeds from a government employee's retirement insurance, for which no beneficiary was designated, should be split equally between his two families from separate marriages. While one wife was named as the sole beneficiary for his life insurance policy, the Court found that retirement insurance and life insurance are separate benefits that require separate beneficiary designations. In the absence of a named beneficiary, the legal heirs from both marriages are entitled to split the retirement insurance proceeds evenly. The Court affirmed the lower court's decision denying the claim of the second wife and her children to the full retirement benefits.

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    Topic: Beneficiaries (Life Insurance) - Statutory Limitations

    Uploaded by

    Anonymous hS0s2mo
    18 views1 page
    The Supreme Court ruled that the proceeds from a government employee's retirement insurance, for which no beneficiary was designated, should be split equally between his two families from separate marriages. While one wife was named as the sole beneficiary for his life insurance policy, the Court found that retirement insurance and life insurance are separate benefits that require separate beneficiary designations. In the absence of a named beneficiary, the legal heirs from both marriages are entitled to split the retirement insurance proceeds evenly. The Court affirmed the lower court's decision denying the claim of the second wife and her children to the full retirement benefits.

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    Consuegra v GSIS

    Original Title

    Consuegra v GSIS

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    The Supreme Court ruled that the proceeds from a government employee's retirement insurance, for which no beneficiary was designated, should be split equally between his two families from separate marriages. While one wife was named as the sole beneficiary for his life insurance policy, the Court found that retirement insurance and life insurance are separate benefits that require separate beneficiary designations. In the absence of a named beneficiary, the legal heirs from both marriages are entitled to split the retirement insurance proceeds evenly. The Court affirmed the lower court's decision denying the claim of the second wife and her children to the full retirement benefits.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    18 views1 page

    Topic: Beneficiaries (Life Insurance) - Statutory Limitations

    Uploaded by

    Anonymous hS0s2mo
    The Supreme Court ruled that the proceeds from a government employee's retirement insurance, for which no beneficiary was designated, should be split equally between his two families from separate marriages. While one wife was named as the sole beneficiary for his life insurance policy, the Court found that retirement insurance and life insurance are separate benefits that require separate beneficiary designations. In the absence of a named beneficiary, the legal heirs from both marriages are entitled to split the retirement insurance proceeds evenly. The Court affirmed the lower court's decision denying the claim of the second wife and her children to the full retirement benefits.

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    Consuegra v GSIS

    37 SCRA 315. January 30, 1971


    En Banc - J. Zaldivar

    Topic: Beneficiaries (Life Insurance) – Statutory Limitations


    FACTS:
    - Jose Consuegra was a shop foreman at the Office of the District Engineer in Surigao Del
    Norte. When he was still alive, he contracted two marriages:
    o 1st: Rosario Diaz; 2 children = Jose Consuegra Jr. and Pedro but both died before he did
    o 2nd: Basilia Berdin; 7 children.  (Marriage wascontracted in good faith while the first
    marriage subsisted)
    - Jose died on September, 1965. Being a GSIS member when he died, the proceeds of his life
    insurance were paid by the GSIS to Berdin and her children who were the beneficiaries
    named in the policy.
    - Since he was in the gov’t service for 22.5028 years, he was entitled to retirement insurance
    benefits, for which no beneficiary was designated.
    - Both families filed their claims with the GSIS, which ruled that the legal heirs were Diaz who
    is entitled to one-half or 8/16 of the retirement benefits and Berdin and her children were
    entitled to the remaining half, each to receive an equal share of 1/16.
    - Berdin went to CFI on appeal.  CFI affirmed GSIS decision.

    ISSUES/HELD/RATIO
    1. W/N retirement insurance benefits should be given solely to petitioner Berdin – No.
    - Berdin: Since we are the only beneficiaries names in the life insurance policy, we should also
    be the only beneficiaries to the retirement insurance benefits.
    - SC: Both families are entitled to half of the retirement benefits.
    - The beneficiary named in the life insurance does NOT automatically become the beneficiary
    in the retirement insurance.  When Consuegra, during the early part of 1943, or before
    1943, designated his beneficiaries in his life insurance, he could NOT have intended those
    beneficiaries of his life insurance as also the beneficiaries of his retirement insurance
    because the provisions on retirement insurance under the GSIS came about only when CA
    186 was amended by RA 660 on June 18, 1951.
    - Sec. 11(b) clearly indicates that there is need for the employee to file an application for
    retirement insurance benefits when he becomes a GSIS member and to state his
    beneficiary.  The life insurance and the retirement insurance are two separate and distinct
    systems of benefits paid out from 2 separate and distinct funds.
    - In case of failure to name a beneficiary in an insurance policy, the proceeds will accrue to
    the estate of the insured.  And when there exists two marriages, each family will be entitled
    to one-half of the estate.

    JUDGMENT: Petition DENIED. Decision appealed from is AFFIRMED.

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