GR 165545; (March, 2006) (Digest)
G.R. No. 165545, March 24, 2006
SOCIAL SECURITY SYSTEM, Petitioner, vs. TERESITA JARQUE VDA. DE BAILON, Respondent.
FACTS
Clemente Bailon’s first wife, Alice Diaz, was declared presumptively dead by the Court of First Instance in 1970. In 1983, Bailon married respondent Teresita Jarque. Upon Bailon’s death in 1998, the SSS initially granted Jarque’s claims for funeral and death benefits as his surviving spouse. However, the SSS later cancelled these benefits upon claims by other individuals, including a daughter from another relationship and a brother of Alice Diaz, asserting that Alice was still alive. The SSS, adopting an internal legal opinion, concluded that Bailon’s marriage to Jarque was void ab initio because the 1970 declaration of presumptive death was allegedly invalidated by Alice’s reappearance, rendering the subsequent marriage bigamous. The Social Security Commission upheld the SSS’s cancellation of benefits.
ISSUE
Whether the Social Security System and the Social Security Commission correctly denied respondent’s claim for death benefits based on a collateral finding that her marriage to the deceased member was void due to the presumed reappearance of his first wife.
RULING
No. The Supreme Court reversed the rulings of the SSC and the Court of Appeals, reinstating respondent’s entitlement to benefits. The Court held that the SSS and the SSC exceeded their jurisdiction. Their mandate under the Social Security Act is limited to determining the claimant’s status as a primary beneficiary based on the validity of the marriage on its face through the documents presented, such as a marriage certificate. They are not vested with judicial authority to annul a marriage or declare it void. The 1970 judicial declaration of presumptive death was issued by a court of competent jurisdiction and, absent a direct judicial challenge and annulment, remains valid and binding for all purposes, including the SSS’s determination of benefits. The subsequent marriage contracted in reliance on that judicial order is considered valid until annulled in a proper judicial proceeding. The alleged reappearance of the first wife does not automatically nullify the second marriage; it merely provides a ground for the aggrieved party to file an action for annulment. Since no such final judicial declaration of nullity was presented, the SSS was legally bound to recognize the marriage certificate and award the benefits to the respondent as the legitimate surviving spouse.