G.R. No. 173582 ; January 28, 2008
YOLANDA SIGNEY, petitioner, vs. SOCIAL SECURITY SYSTEM, EDITHA ESPINOSA-CASTILLO, and GINA SERVANO, representative of GINALYN and RODELYN SIGNEY, respondents.

FACTS

Rodolfo Signey, Sr., an SSS member, died on May 21, 2001. His SSS records designated Yolanda Signey as the primary beneficiary and their four children as secondary beneficiaries. Yolanda filed a claim for death benefits. However, it was subsequently revealed that Rodolfo had a prior subsisting marriage to Editha Espinosa-Castillo contracted in 1967, which rendered his 1992 marriage to Yolanda null and void. Another claimant, Gina Servano, also a common-law wife, filed a claim on behalf of her two minor children with the deceased. Editha also filed a claim but later executed a waiver, stating she was not married to Rodolfo and had no claim to the benefits.
The SSS denied Yolanda’s claim, recognizing instead Gina’s two minor children, Ginalyn and Rodelyn, as the primary beneficiaries. The Social Security Commission (SSC) affirmed this, giving more weight to the certified marriage certificate between Rodolfo and Editha than to Editha’s subsequent waiver. The SSC found Editha was not dependent on Rodolfo for support due to her cohabitation with another man. Yolanda’s children were all over 21 years old at the time of Rodolfo’s death and thus not considered dependent minors. The Court of Appeals sustained the SSC’s resolution.

ISSUE

Who is entitled to the social security death benefits of the deceased SSS member?

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic centers on the application of the SSS Law ( R.A. No. 8282 ), which statutorily defines primary beneficiaries, superseding any member designation. Under Section 8(e), the primary beneficiaries are the dependent legal spouse and the dependent legitimate, legitimated, legally adopted, and illegitimate children. Here, the legal spouse, Editha, was disqualified because she was not dependent for support, as she was cohabiting with another man. Yolanda, not being the legal wife, had no claim as a primary beneficiary.
The Court upheld the SSC’s factual finding, based on substantial evidence, of a prior valid marriage between Rodolfo and Editha, rendering Yolanda’s marriage void. Consequently, the dependent illegitimate minor children became the primary beneficiaries under Section 8(k). Yolanda’s children were over 21 and not proven dependent, whereas Gina’s children, Ginalyn and Rodelyn, were minors at the time of Rodolfo’s death and were therefore presumed dependent under the law. The waiver executed by Editha was correctly disregarded as it could not negate the established fact of the prior marriage and, in any event, she had no right to waive as she was not a qualified beneficiary. The member’s designation in favor of Yolanda was ineffective against the statutory order of preference.