Lessons Applicable: To whom insurance proceeds payable (Insurance)

FACTS:

Loreto Maramag designated as beneficiary his concubine Eva de Guzman Maramag

Vicenta Maramag and Odessa, Karl Brian, and Trisha Angelie (heirs of Loreto

Maramag) and his concubine Eva de Guzman Maramag, also suspected in the killing

of Loreto and his illegitimate children are claiming for his insurance.

Vicenta alleges that Eva is disqualified from claiming

RTC: Granted - civil code does NOT apply

CA: dismissed the case for lack of jurisdiction for filing beyond reglementary period

ISSUE: W/N Eva can claim even though prohibited under the civil code against donation

HELD: YES. Petition is DENIED. 

Any person who is forbidden from receiving any donation under Article 739 cannot

be named beneficiary of a life insurance policy of the person who cannot make any

donation to him

If a concubine is made the beneficiary, it is believed that the insurance contract will

still remain valid, but the indemnity must go to the legal heirs and not to the

concubine, for evidently, what is prohibited under Art. 2012 is the naming of the

improper beneficiary. 

SECTION 53. The insurance proceeds shall be applied exclusively to the proper

interest of the person in whose name or for whose benefit it is made unless

otherwise specified in the policy.

GR: only persons entitled to claim the insurance proceeds are either the insured, if

still alive; or the beneficiary, if the insured is already deceased, upon the maturation

of the policy.

EX: situation where the insurance contract was intended to benefit third persons

who are not parties to the same in the form of favorable stipulations or indemnity. In

such a case, third parties may directly sue and claim from the insurer

It is only in cases where the insured has not designated any beneficiary, or when the

designated beneficiary is disqualified by law to receive the proceeds, that the

insurance policy proceeds shall redound to the benefit of the estate of the insured