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Insurance Case Digest: Social Security System v. Davac (1966)

G.R. No. L-21642             July 30, 1966
Lessons Applicable: Invalid Designation (Insurance)

FACTS:
  • Petronilo Davac, a former employee of Lianga Bay Logging Co., Inc. became a member of the Social Security System (SSS) he designated Candelaria Davac as his beneficiary and indicated his relationship to her as that of "wife"
  • Lourdes Tuplano his legal wife and their son Romeo Davac and Candelaria Davac and their minor daughter Elizabeth Davac filed their claims
  • Social Security Commission: Candelaria Davac 
ISSUE: W/N Candelaria Davac can claim and New Civil Code 739 is not applicable

HELD: YES. 
  • she was not guilty of concubinage, there being no proof that she had knowledge of the previous marriage of her husband Petronilo
  • The amounts that may thus be received cannot be considered as property earned by the member during his lifetime
  • if there is a named beneficiary and the designation is not invalid (as it is not so in this case), it is not the heirs of the employee who are entitled to receive the benefits (unless they are the designated beneficiaries themselves). It is only when there is no designated beneficiaries or when the designation is void, that the laws of succession are applicable. And we have already held that the Social Security Act is not a law of succession.