G.R. No. 165546 ; February 27, 2006
SOCIAL SECURITY SYSTEM, Petitioner, vs. ROSANNA H. AGUAS, JANET H. AGUAS, and minor JEYLNN H. AGUAS, represented by her Legal Guardian, ROSANNA H. AGUAS, Respondents.

FACTS

Pablo Aguas, an SSS member and pensioner, died in 1996. His widow, Rosanna, filed for death benefits, listing their minor child, Jeylnn, as a co-beneficiary. The SSS initially granted the monthly pension. However, the SSS later received a sworn letter from Pablo’s sister, Leticia, alleging that Rosanna had abandoned Pablo years prior, lived with another man, and that Jeylnn was not Pablo’s child. Leticia submitted a birth certificate for another child, Jefren, showing Romeo dela Peña as the father. Based on an investigation report citing neighbor interviews and an alleged medical opinion on Pablo’s infertility, the SSS suspended the pensions and demanded a refund of amounts already paid.
Rosanna, Jeylnn, and another claimant, Janet, contested the denial before the Social Security Commission (SSC). They presented their marriage certificate, the children’s birth certificates (with Pablo listed as father and bearing his signature), a joint affidavit from neighbors attesting to their cohabitation, and a denial from the doctor regarding the infertility claim. The SSC, after hearings and a handwriting analysis confirming Pablo’s signature on Jeylnn’s birth certificate, ruled in favor of the claimants. The Court of Appeals affirmed this decision.

ISSUE

Whether the Social Security Commission and the Court of Appeals erred in granting the claim for death benefits in favor of Rosanna and the children.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ decisions. The legal logic centers on the conclusive presumption of legitimacy under the Family Code and the proper procedure for impugning filiation. A child born during a valid marriage is presumed legitimate. This presumption can only be contested through a direct action for impugning legitimacy, which is strictly time-bound and must be filed by the husband or, in limited cases, his heirs. The SSS is not among the parties authorized by law to file such an action.
The allegations of abandonment, adultery, and non-paternity, while raised by a private individual and investigated by the SSS, do not constitute a proper judicial challenge to legitimacy. The birth certificates, which are public documents, and the corroborative evidence presented by the claimants, stand as prima facie evidence of filiation. The SSS, in adjudicating benefit claims, cannot disregard this presumption and assume the role of a court to declare a child illegitimate based on mere investigative reports. Therefore, in the absence of a final judicial declaration disclaiming the children’s legitimacy, the SSS is legally obligated to recognize them as primary beneficiaries entitled to death benefits.