Dycaico v.

SSS
G.R. No. 161357
November 30, 2005
FACTS:
Bonifacio S. Dycaico became a member of the SSS on January 24, 1980. In his self-employed
data, he named the petitioner, Elena P. Dycaico, and their 8 children as his beneficiaries. At that
time, Bonifacio and Elena lived together as husband and wife without the benefit of marriage.
In June 1989, Bonifacio was considered retired and began receiving his monthly pension from
the SSS. He continued to receive the monthly pension until he passed away on June 19, 1997.
A few months prior to his death, however, Bonifacio married the petitioner on January 6, 1997.
Shortly after Bonifacios death, the petitioner filed with the SSS an application for survivors
pension. Her application, however, was denied on the ground that under the Social Security Law
she could not be considered a primary beneficiary of Bonifacio as of the date of his retirement.
The petitioner filed with the SSC a petition alleging that the denial of her survivors pension was
unjustified. She contended that Bonifacio designated her and their children as primary
beneficiaries in his SSS Form RS-1 and that it was not indicated therein that only legitimate
family members could be made beneficiaries.
The SSC promulgated its Resolution affirming the denial of the petitioners claim. The SSC
refuted the petitioners contention that primary beneficiaries need not be legitimate family
members by citing the definitions of primary beneficiaries and dependents.
Aggrieved, the petitioner filed with the CA a petition for review of the SSCs February 6,
2002 Resolution. In the assailed Decision, the appellate court dismissed the petition. The CA
declared that since the petitioner was merely the common-law wife of Bonifacio at the time of
his retirement, his designation of the petitioner as one of his beneficiaries in the SSS Form RS-1
in 1980 is void. The CA further observed that Bonifacios children with the petitioner could no
longer qualify as primary beneficiaries because they have all reached 21 years of age.
ISSUE:
WON Dycaico can be considered as a beneficiary.
WON there is a violation to equal protection clause of the Constitution.
HELD:
Classifying dependent spouses and determining their entitlement to survivors pension based on
whether the marriage was contracted before or after the retirement of the other spouse bears no
relation to the achievement of the policy objective of the law.
Indeed, the SC does not find substantial distinction between spouses whose assignment as a
beneficiary was made after the marriage and spouses whose assignment as a beneficiary was
made before the marriage. The statute violates equal protection clause when it grants surviving
pensions only to the spouses belonging to the former case and not to than the latter.

A statute, to be valid and reasonable, must satisfy the following requirements: must satisfy the
following requirements: (1) it must rest on substantial distinctions; (2) it must be germane to the
purpose of the law; (3) it must not be limited to existing conditions only; and (4) it must apply
equally to all members of the same class.
As illustrated by the petitioners case, the proviso as of the date of his retirement in Section 12B(d) of Rep. Act No. 8282 which qualifies the term primary beneficiaries results in the
classification of dependent spouses as primary beneficiaries into two groups:
(1) Those dependent spouses whose respective marriages to SSS members were
contracted prior to the latters retirement; and
(2) Those dependent spouses whose respective marriages to SSS members were
contracted after the latters retirement.
Underlying these two classifications of dependent spouses is that their respective marriages are
valid. In other words, both groups are legitimate or legal spouses. The distinction between them
lies solely on the date the marriage was contracted. The petitioner belongs to the second group
of dependent spouses, i.e., her marriage to Bonifacio was contracted after his retirement. As
such, she and those similarly situated do not qualify as primary beneficiaries under Section 12B(d) of Rep. Act No. 8282 and, therefore, are not entitled to survivors pension under the same
provision by reason of the subject proviso.
Further, the classification of dependent spouses on the basis of whether their respective
marriages to the SSS member were contracted prior to or after the latters retirement for the
purpose of entitlement to survivors pension does not rest on real and substantial distinctions. It
is arbitrary and discriminatory. It is too sweeping because the proviso as of the date of his
retirement, which effectively disqualifies the dependent spouses whose respective marriages to
the retired SSS member were contracted after the latters retirement as primary beneficiaries,
unfairly lumps all these marriages as sham relationships or were contracted solely for the
purpose of acquiring benefits accruing upon the death of the other spouse.
WHEREFORE, the petition is GRANTED. The Decision dated April 15, 2003 and Resolution
dated December 15, 2003 of the Court of Appeals in CA-G.R. SP No. 69632
are REVERSED and SET ASIDE. The proviso as of the date of his retirement in Section 12-B(d)
of Rep. Act No. 8282 is declared VOID for being contrary to the due process and equal
protection clauses of the Constitution. The Social Security System cannot deny the claim of
petitioner Elena P. Dycaico for survivors pension on the basis of this invalid proviso.

GSIS v. Raoet
G.R. No. 157038
December 23, 2009
FACTS:
The respondents husband, Francisco M. Raoet (Francisco), entered govt service on July 16,
1974 as an Engineer Trainee at the National Irrigation Administration (NIA).On July 5, 1978, he
was appointed as Junior Civil Engineer, and on April 22, 1981, he rose to the rank of Irrigation
Engineer B. On August 1, 1998, he was promoted to the position of Engineer A the position he
held until his death on May 5, 2001.
In 2000, Francisco was diagnosed with Hypertension, Severe, Stage III, Coronary Artery
Disease, and he was confined at the Region I Medical Center from July 16 to July 25, 2000. As
the GSIS considered this a work-related condition, Francisco was awarded 30 days Temporary
Total Disability benefits, plus reimbursement of medical expenses incurred during treatment.
On May 5, 2001, Francisco was rushed to the Dr. Marcelo M. Chan Memorial Hospital because
he was vomiting blood. He was pronounced dead on arrival at the hospital. His death certificate
listed the causes of his death as cardiac arrest with underlying cause of peptic ulcer disease.
The respondent, as widow, filed with the GSIS on May 24, 2001 a claim for income benefits
accruing from the death of her husband. The GSIS denied the claim on the ground that the
respondent did not submit any supporting documents to show that Franciscos death was due to
peptic ulcer.
On appeal, the ECC affirmed the findings of the GSIS in its decision of July 24, 2002. According
to the ECC, it could not determine if Franciscos death was compensable due to the absence of
documents supporting the respondents claim. Since Francisco had no prior history of
consultation relating to peptic ulcer and no autopsy was performed to ascertain the cause of his
death, the ECC could not conclude that Bleeding Peptic Ulcer Disease was the reason for his
demise.
CA reversed the ECC decision. It held that while the Amended Rules on Employees
Compensation does not list peptic ulcer as an occupational disease, Franciscos death should
be compensable since its immediate cause was cardiac arrest.
ISSUE:
WON the ailment Acute Massive Hemorrhage t/c Bleeding Peptic Ulcer Disease, which caused
the death of the late Francisco, is work-connected or whether there was any proof to show that
the risk of contracting the same was increased by factors attendant to his employment and if
respondent can be given the income benefit for it.
HELD:
Based on Franciscos death certificate, the immediate cause of his death was cardiac arrest; the
antecedent cause was acute massive hemorrhage, and the underlying cause was bleeding
peptic ulcer disease. We find that the respondent submitted sufficient proof of the cause of her
husbands death when she presented his death certificate. We held that death certificates and
the notes by a municipal health officer prepared in the regular performance of his

duties are prima facie evidence of facts therein stated. A duly-registered death
certificate is considered a public document and the entries found therein are presumed
correct, unless the party who contests its accuracy can produce positive evidence establishing
a contrary conclusion.
We stress that in determining the compensability of an illness, we do not require that the
employment be the sole factor in the growth, development, or acceleration of a claimants illness
to entitle him to the benefits provided for. It is enough that his employment contributed, even if
only in a small degree, to the development of the disease.
In this case, the chain of causation that led to the peptic ulcer is too obvious to be
disregarded. The pressures of Franciscos work constant, continuing and consistent at his level
of responsibility inevitably manifested their physical effects on Franciscos health and body; the
initial and most obvious were the hypertension and coronary artery disease that the GSIS itself
recognized. Less obvious, but nevertheless arising from the same pressures and stresses, were
the silent killers, like peptic ulcer, that might not have attracted Franciscos attention to the point
of driving him to seek immediate and active medical intervention. Ultimately, when the ulcerproducing stresses did not end, his ulcer bled profusely, affecting his heart and causing its
arrest. In this manner, Francisco died. That his widow should now be granted benefits for
Franciscos death is a conclusion we cannot avoid and is, in fact, one that we should gladly
make as a matter of law and social justice.