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    Heirs of L.G. Maramag v. Maramag

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    Sopongco Coleen
    This case involves a dispute over life insurance proceeds between the heirs of Loreto Maramag and his designated beneficiary, Eva de Guzman Maramag, who was Loreto's concubine. Under the Civil Code, a concubine is prohibited from receiving donations. The Supreme Court held that while the insurance contract remains valid, the proceeds cannot go to the concubine since she is an improper beneficiary under the law. Instead, the proceeds must go to Loreto's legal heirs. Only the insured, a validly designated beneficiary, or the insured's estate are entitled to claim the insurance proceeds.

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    Heirs of L.G. Maramag v. Maramag

    Uploaded by

    Sopongco Coleen
    68 views2 pages
    This case involves a dispute over life insurance proceeds between the heirs of Loreto Maramag and his designated beneficiary, Eva de Guzman Maramag, who was Loreto's concubine. Under the Civil Code, a concubine is prohibited from receiving donations. The Supreme Court held that while the insurance contract remains valid, the proceeds cannot go to the concubine since she is an improper beneficiary under the law. Instead, the proceeds must go to Loreto's legal heirs. Only the insured, a validly designated beneficiary, or the insured's estate are entitled to claim the insurance proceeds.

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    This case involves a dispute over life insurance proceeds between the heirs of Loreto Maramag and his designated beneficiary, Eva de Guzman Maramag, who was Loreto's concubine. Under the Civil Code, a concubine is prohibited from receiving donations. The Supreme Court held that while the insurance contract remains valid, the proceeds cannot go to the concubine since she is an improper beneficiary under the law. Instead, the proceeds must go to Loreto's legal heirs. Only the insured, a validly designated beneficiary, or the insured's estate are entitled to claim the insurance proceeds.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    68 views2 pages

    Heirs of L.G. Maramag v. Maramag

    Uploaded by

    Sopongco Coleen
    This case involves a dispute over life insurance proceeds between the heirs of Loreto Maramag and his designated beneficiary, Eva de Guzman Maramag, who was Loreto's concubine. Under the Civil Code, a concubine is prohibited from receiving donations. The Supreme Court held that while the insurance contract remains valid, the proceeds cannot go to the concubine since she is an improper beneficiary under the law. Instead, the proceeds must go to Loreto's legal heirs. Only the insured, a validly designated beneficiary, or the insured's estate are entitled to claim the insurance proceeds.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    Heirs Of Loreto C.

    Maramag V Maramag
    (2009)
    G.R. No. 181132              June 5, 2009
    Lessons Applicable: To whom insurance proceeds payable (Insurance)

    FACTS:
     Loreto Maramag designated as beneficiary his concubine Eva de Guzman
    Maramag
     Vicenta Maramag and Odessa, Karl Brian, and Trisha Angelie (heirs of Loreto
    Maramag) and his concubine Eva de Guzman Maramag, also suspected in the killing
    of Loreto and his illegitimate children are claiming for his insurance.
     Vicenta alleges that Eva is disqualified from claiming
     RTC: Granted - civil code does NOT apply
     CA: dismissed the case for lack of jurisdiction for filing beyond reglementary
    period
    ISSUE: W/N Eva can claim even though prohibited under the civil code against donation

    HELD: YES. Petition is DENIED. 


     Any person who is forbidden from receiving any donation under Article 739
    cannot be named beneficiary of a life insurance policy of the person who cannot
    make any donation to him
     If a concubine is made the beneficiary, it is believed that the insurance
    contract will still remain valid, but the indemnity must go to the legal heirs and not
    to the concubine, for evidently, what is prohibited under Art. 2012 is the naming of
    the improper beneficiary. 
     SECTION 53. The insurance proceeds shall be applied exclusively to the proper
    interest of the person in whose name or for whose benefit it is made unless
    otherwise specified in the policy.

    xxxxxxxxxxx
    o GR: only persons entitled to claim the insurance proceeds are either the
    insured, if still alive; or the beneficiary, if the insured is already deceased, upon the
    maturation of the policy.
    o EX: situation where the insurance contract was intended to benefit third
    persons who are not parties to the same in the form of favorable stipulations or
    indemnity. In such a case, third parties may directly sue and claim from the insurer
     It is only in cases where the insured has not designated any beneficiary, or when
    the designated beneficiary is disqualified by law to receive the proceeds, that the
    insurance policy proceeds shall redound to the benefit of the estate of the insured

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