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Insurance Case Digest Heirs of Loreto C. Maramag V Maramag (2009)

1) Loreto Maramag designated his concubine, Ma de Guzman Maramag, as the beneficiary of his life insurance policy. However, his heirs argued that Ma was disqualified from claiming the proceeds. 2) The Supreme Court ruled that while a concubine is prohibited from receiving donations under the Civil Code, this does not prevent them from being named as a beneficiary of a life insurance policy. 3) However, the insurance proceeds must go to the legal heirs, not the concubine, as naming an improper beneficiary is prohibited. Therefore, Ma could not claim the insurance proceeds.

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0% found this document useful (0 votes)
604 views1 page

Insurance Case Digest Heirs of Loreto C. Maramag V Maramag (2009)

1) Loreto Maramag designated his concubine, Ma de Guzman Maramag, as the beneficiary of his life insurance policy. However, his heirs argued that Ma was disqualified from claiming the proceeds. 2) The Supreme Court ruled that while a concubine is prohibited from receiving donations under the Civil Code, this does not prevent them from being named as a beneficiary of a life insurance policy. 3) However, the insurance proceeds must go to the legal heirs, not the concubine, as naming an improper beneficiary is prohibited. Therefore, Ma could not claim the insurance proceeds.

Uploaded by

Ping Edulan
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Insurance Case Digest: Heirs Of Loreto C.

Maramag
V Maramag (2009)
G.R. No. 181132 June 5, 2009
Lessons Applicable: To whom insurance proceeds payable (Insurance)
A!T":
Lore#o $arama% desi%na#ed as bene&iciary his concubine '(a de )u*man $arama%
+icen#a $arama% and ,dessa, -arl .rian, and Trisha An%elie (heirs o& Lore#o $arama%) and
his concubine '(a de )u*man $arama%, also suspec#ed in #he /illin% o& Lore#o and his ille%i#ima#e
children are claimin% &or his insurance0
+icen#a alle%es #ha# '(a is dis1uali&ied &rom claimin%
2T!: )ran#ed 3 ci(il code does 4,T apply
!A: dismissed #he case &or lac/ o& 5urisdic#ion &or &ilin% beyond re%lemen#ary period
I""6': 784 '(a can claim e(en #hou%h prohibi#ed under #he ci(il code a%ains# dona#ion
9'L:: ;'"0 <e#i#ion is :'4I':0
Any person who is &orbidden &rom recei(in% any dona#ion under Ar#icle =>9 canno# be named
bene&iciary o& a li&e insurance policy o& #he person who canno# ma/e any dona#ion #o him
I& a concubine is made #he bene&iciary, i# is belie(ed #ha# #he insurance con#rac# will
s#ill remain (alid, bu# #he indemni#y mus# %o #o #he le%al heirs and no# #o #he concubine, &or
e(iden#ly, wha# is prohibi#ed under Ar#0 20?2 is #he namin% o& #he improper bene&iciary0
"'!TI,4 5>0 The insurance proceeds shall be applied e@clusi(ely #o #he proper in#eres# o& #he
person in whose name or &or whose bene&i# i# is made unless o#herwise speci&ied in #he policy0
)2: only persons en#i#led #o claim #he insurance proceeds are ei#her #he insured, i& s#ill
ali(eA or #he bene&iciary, i& #he insured is already deceased, upon #he ma#ura#ion o& #he policy0
'B: si#ua#ion where #he insurance con#rac# was in#ended #o bene&i# #hird persons who
are no# par#ies #o #he same in #he &orm o& &a(orable s#ipula#ions or indemni#y0 In such a case, #hird
par#ies may direc#ly sue and claim &rom #he insurer
I# is only in cases where #he insured has no# desi%na#ed any bene&iciary, or when #he
desi%na#ed bene&iciary is dis1uali&ied by law #o recei(e #he proceeds, #ha# #he insurance policy
proceeds shall redound #o #he bene&i# o& #he es#a#e o& #he insured

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