Heirs of Loreto C. Maramag v. Eva Verna de Guzman Maramag

Summary

The legitimate heirs of Loreto Maramag challenged insurance proceeds designated to his illegitimate family, arguing that his concubine Eva should be disqualified and illegitimate children entitled to reduced shares under succession laws. The Supreme Court upheld the dismissal of their petition for failure to state a cause of action. The Court ruled that insurance contracts are governed by the Insurance Code, not Civil Code provisions on donations or succession. Under Section 53 of the Insurance Code, insurance proceeds belong exclusively to designated beneficiaries. As third parties to the insurance contracts, the legitimate heirs had no legal right to claim the proceeds. The designation of illegitimate children as beneficiaries remained valid, as no law prohibits naming children of illicit relationships as insurance beneficiaries. This case clarifies the primacy of insurance law over succession law in determining beneficiary rights.