Heirs Vs Maramag

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49.

Heirs of Loreto Maramag vs Maramag 2009


Facts: The petition alleged that: (1) petitioners were the legitimate wife and children of Loreto Maramag
(Loreto), while respondents were Loreto's illegitimate family; (2) Eva de Guzman Maramag (Eva) was a
concubine of Loreto and a suspect in the killing of the latter, thus, she is disqualified to receive any proceeds
from his insurance policies from Insular Life Assurance Company, Ltd. (Insular) and Great Pacific Life Assurance
Corporation (Grepalife);(3) the illegitimate children of Loreto Odessa, Karl Brian, and Trisha Angelie were
entitled only to one-half of the legitime of the legitimate children, thus, the proceeds released to Odessa and
those to be released to Karl Brian and Trisha Angelie were inofficious and should be reduced; and (4)
petitioners could not be deprived of their legitimes, which should be satisfied first.
Although petitioners are the legitimate heirs of Loreto, they were not named as beneficiaries in the insurance
policies issued by Insular and Grepalife. They also argued that pursuant to Section 12 of the Insurance Code,
Eva's share in the proceeds should be forfeited in their favor, the former having brought about the death of
Loreto.
Issue: Are the members of the legitimate family entitled to the proceeds of the insurance for the concubine?
Ruling: No. 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. The exception to this rule is
a 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.
Petitioners are third parties to the insurance contracts with Insular and Grepalife and, thus, are not entitled to
the proceeds thereof. Accordingly, respondents Insular and Grepalife have no legal obligation to turn over the
insurance proceeds to petitioners. The revocation of Eva as a beneficiary in one policy and her disqualification
as such in another are of no moment considering that the designation of the illegitimate children as
beneficiaries in Loreto's insurance policies remains valid. Because no legal proscription exists in naming as
beneficiaries the children of illicit relationships by the insured, the shares of Eva in the insurance proceeds,
whether forfeited by the court in view of the prohibition on donations under Article 739 of the Civil Code or by
the insurers themselves for reasons based on the insurance contracts, must be awarded to the said
illegitimate children, the designated beneficiaries, to the exclusion of petitioners. 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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