G.R. No. 164947 ; January 31, 2006
SONIA MACEDA ALIAS SONIALITA MACEDA AND GEMMA MACEDA-MACATANGAY, Petitioners, vs. ENCARNACION DE GUZMAN VDA. DE MACATANGAY, Respondent.

FACTS

Petitioner Sonia Maceda and Bonifacio Macatangay were lawfully married in 1964 and had one child, petitioner Gemma. The couple separated shortly thereafter and executed a “Kasunduan” in 1967 agreeing to live apart. Bonifacio subsequently cohabited with Carmen Jaraza, with whom he had three children. Upon Bonifacio’s death in 1998, a dispute arose over his Social Security System (SSS) death benefits. The SSS initially denied the claim of his common-law wife, Carmen. Petitioner Sonia, the legal spouse, then filed and was granted the benefits, receiving a lump sum.
Subsequently, Bonifacio’s mother, respondent Encarnacion de Guzman Vda. de Macatangay, filed a petition before the Social Security Commission (SSC). She claimed her son had designated her and his three illegitimate children as his SSS beneficiaries. The SSC ruled in her favor, ordering Sonia to refund the benefits received. The SSC held that the “Kasunduan” proved Sonia was not actually dependent on Bonifacio for support, thus disqualifying her as a primary beneficiary. The Court of Appeals dismissed petitioners’ appeal on procedural grounds.

ISSUE

Whether the legal spouse, Sonia Maceda, is disqualified as the primary beneficiary of her deceased husband’s SSS benefits due to a private separation agreement and alleged lack of dependency for support.

RULING

No. The Supreme Court reversed the SSC and the Court of Appeals, reinstating Sonia Maceda as the rightful beneficiary. The legal logic is anchored on a clear statutory interpretation of Republic Act No. 8282 , the Social Security Act of 1997. The law explicitly defines the “dependent spouse” as the “legal spouse entitled by law to receive support from the member.” Dependency is a legal conclusion based on the marital status, not a factual condition to be proven.
The Court emphasized that the right to support between spouses is mandated by the Family Code and arises from the marriage itself. The private “Kasunduan” wherein the couple agreed to live separately is void for being contrary to law and public policy, as it seeks to alter the essential obligations of marriage. It cannot negate the legal entitlement to support. Therefore, Sonia, as the lawful wife who never remarried, is conclusively presumed to be a dependent spouse under the law. The SSS correctly awarded her the benefits as the primary beneficiary. The designation of other beneficiaries by the member is irrelevant in the presence of a dependent legal spouse.