GR L 18529; (February, 1965) (Digest)
G.R. No. L-18529 February 26, 1965
FRANCISCO G. ALEJA, FELICITACION GAMBOA-ALEJA and DOMINADOR ALEJA, plaintiffs-appellants, vs. GOVERNMENT SERVICE INSURANCE SYSTEM, defendant-appellee.
FACTS
The deceased Rosauro G. Aleja was appointed as a temporary classroom teacher on July 8, 1958. A compulsory term insurance policy (No. 310973) was issued in his name, with its effective date specified as February 1, 1959. The first premium deduction from his salary occurred on January 31, 1959. However, Rosauro Aleja died from a gunshot wound on January 29, 1959. The plaintiffs, as named beneficiaries, filed a claim with the GSIS for the policy proceeds. The GSIS denied the claim, asserting that the policy was not yet effective at the time of death. The Court of First Instance of Nueva Ecija dismissed the plaintiffs’ complaint, prompting this appeal.
ISSUE
Whether Rosauro G. Aleja was covered by compulsory insurance under the GSIS at the time of his death on January 29, 1959.
RULING
No. The Supreme Court affirmed the denial of the insurance claim. The compulsory insurance coverage for an employee under Commonwealth Act No. 186 , as amended, becomes effective “on the first day of the seventh calendar month following the month he was appointed.” Since Rosauro Aleja was appointed in July 1958, the seventh calendar month following would be February 1959, making the coverage effective on February 1, 1959. His death on January 29, 1959, occurred before this effective date. The Court found the statutory classification for determining the effectivity date, while creating a distinction based on appointment date, was not unreasonable, arbitrary, or capricious, as it was germane to administrative efficiency. Furthermore, the insurance contract itself specified February 1, 1959, as the effective date, and the first premium was deducted after Aleja’s death, meaning no valid contract with consideration existed at the time of the peril. The Court modified the lower court’s decision by ordering the GSIS to return the premium amount deducted from the deceased’s salary.