Social Security System v. De los Santos
REITERATIONFacts
The Antecedents: Antonio de los Santos and Gloria de los Santos were married in 1964. Gloria left Antonio less than a year later, remarried, and then returned to Antonio in 1969, living with him until 1983. In 1983, Gloria left Antonio again, went to the United States, and obtained a divorce from him in 1986. She subsequently married an American citizen. Antonio also remarried in 1987 and had a child with his second wife. Antonio retired in 1996 and began receiving a pension, later dying in 1999. Procedural History: Following Antonio's death, his second wife, Cirila, began receiving his SSS pension. Gloria filed a claim for death benefits with the SSS, which was denied because she was not considered a qualified beneficiary due to her remarriage and the divorce she obtained. Gloria appealed to the Social Security Commission (SSC), which impleaded Cirila. The SSC denied Gloria's petition, ruling that Antonio's daughter with Cirila, May-Ann, was the rightful secondary beneficiary. Gloria then appealed to the Court of Appeals (CA), which reversed the SSC's decision, finding Gloria to be the legal wife and thus a qualified primary beneficiary entitled to the benefits. The Petition: The Social Security System (SSS) and its branch manager filed this petition for review on certiorari with the Supreme Court, challenging the CA's decision. The sole issue presented is whether the CA erred in holding that respondent Gloria de los Santos is still qualified as a primary beneficiary of the deceased SSS member Antonio. The SSS argues that Gloria is disqualified because she is not a dependent spouse, having abandoned Antonio, obtained a divorce abroad, and remarried, thus failing to meet the dependency requirement under the Social Security Law.
Issue(s)
Whether respondent Gloria de los Santos is still qualified as a primary beneficiary of the deceased SSS member Antonio de los Santos. Whether the proviso "as of the date of his retirement" in Section 12-B(d) of Republic Act No. 8282 is constitutional.
Ruling
The petition is GRANTED. The appealed Decision of the Court of Appeals is REVERSED and SET ASIDE. The Resolution of the Social Security Commission is REINSTATED.
Ratio Decidendi
On the qualification of respondent Gloria de los Santos as a primary beneficiary: The Supreme Court ruled that while the divorce obtained by respondent Gloria against the deceased Antonio was not binding in the Philippines, she is still disqualified to be his primary beneficiary under the Social Security Law. This disqualification stems from her failure to fulfill the requirement of dependency upon her deceased husband Antonio. The Court cited Social Security System v. Aguas, which held that dependency for support cannot be presumed from marriage alone. A wife who left her family and lived with other men for extended periods, as admitted by respondent, cannot be considered dependent for support, financially or otherwise, during those times. These uncontroverted facts remove her from qualifying as a primary beneficiary of her deceased husband. On the constitutionality of the proviso "as of the date of his retirement" in Section 12-B(d) of Republic Act No. 8282: The Court noted that in Dycaico v. Social Security System, it ruled this proviso unconstitutional for violating due process and equal protection clauses. However, the Court clarified that in the present case, the Dycaico ruling does not substantially affect the determination of Antonio's beneficiaries because the reckoning point for determining beneficiaries should be the time of his death, not his retirement. Regardless of the timing of the marriage relative to retirement, the primary issue remained whether Gloria was a dependent spouse at the time of Antonio's death.
Main Doctrine
An estranged wife who was not dependent upon her deceased husband for support is not qualified to be his beneficiary under the Social Security Law, even if her foreign divorce is not recognized in the Philippines.