GR L 20445; (February, 1967) (Digest)
G.R. No. L-20445 February 25, 1967
ANICIA V. MERCED, CANDELARIO V. MERCED, CONCEPCION V. MERCED, ATILANO V. MERCED, JR., and JOSEFINA V. MERCED, petitioners, vs. COLOMBINA VDA. DE MERCED, BRICCIO MERCED, JR., and the SOCIAL SECURITY SYSTEM, respondents.
FACTS
The deceased Briccio V. Merced, an employee, became a member of the Social Security System (SSS) in 1957. While still single, he designated his brothers and sisters (the petitioners) as his beneficiaries. On May 29, 1960, Briccio married respondent Columbina Merced, who bore him a child, Briccio Jr. Briccio died on February 22, 1961. The petitioners filed a claim for his death benefits, but the SSS Administrator declared the designation in their favor null and void pursuant to a Commission resolution and instead approved payment to Columbina and Briccio Jr. as the legal heirs. The Social Security Commission dismissed the petitioners’ petition and affirmed the Administrator’s action, prompting this appeal.
ISSUE
Whether the designation of the petitioners (brothers and sisters) as beneficiaries by the then-single member Briccio V. Merced remains valid and effective, entitling them to the death benefits, despite his subsequent marriage and the birth of a legitimate child.
RULING
No. The designation is null and void, and the death benefits properly belong to the legitimate spouse and child. The right to designate beneficiaries under the Social Security Act is subject to statutory limitations. At the time of Briccio’s death, Republic Act No. 2658 (amending the Social Security Act) was in force. Under its provisions, a member may designate beneficiaries only from a specified order of priority: first, the legitimate spouse and legitimate children; second, in default of the first, the legitimate parents; and third, in the absence of the foregoing, any other person. Since Briccio died leaving a legitimate spouse (Columbina) and a legitimate child (Briccio Jr.), the petitioners, as brothers and sisters, fall outside the permissible classes of beneficiaries under the law. Furthermore, no vested right to the benefits accrues until the member’s death, and Congress reserved the power to amend the law. Thus, the Commission correctly dismissed the petition and ordered payment to the legitimate heirs.