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Philamlife vs Honorable Gregorio Pineda and Inevitably, based on the law and their contract, it is

Rodolfo Dimayuga only with consent of the beneficiaries that any


July 19, 1989 change or amendment in the policy concerning the
Paras, J.: irrevocable beneficiaries may be legally and validly
executed.
Insurance: Ordinary life insurance policy On his contention that the Court may grant the
amendment for reasonable grounds, it is evident
I. FACTS: that both the law and the policy do not provide for
any other exception.
On January 15, 1968, Private respondent, Rodolfo
Dimayuga, procured an ordinary life insurance policy On the other contention that his children
from Philamlife and designated his wife and children acquiesced, it is obvious that minors cannot validly
as beneficiaries of said policy. give their consent.

Under date Feb. 22, 1980, private respondent filed a Of equal importance is the well-settled rule that the
petition with CFI of Rizal to amend the designation of contract between the parties is the law binding on
the beneficiaries from ‘irrevocable’ to ‘revocable’. both of them. Where there is nothing in the contract
NOTE: His wife died and children are still all minors. which is contrary to law, good morals, etc., the
validity of contract must be sustained.
Rodolfo’s contentions were that:
a. Said designation can be amended if the IV. DISPOSITIVE
Court finds a just, reasonable ground to do
so. WHEREFORE, premises considered, the questioned
b. His 6 minor children (at that time) Orders of the respondent Judge are hereby nullified
acquiesced to the amendment and set aside.

Petitioner filed an Urgent Motion to Reset Hearing


and its Opposition to the Petition, but both were
denied by Respondent judge. The latter granted the
petition of private respondent amending the
designation of beneficiaries.

MR was denied. Hence, this petition.

II. ISSUE:

W/N designation of irrevocable beneficiaries could


be amended without consent of all irrevocable
beneficiaries – NO.

III. RULING:

Under the Insurance Act, beneficiary designated in a


life insurance contract cannot be changed without
the consent of the beneficiary because he has a
vested interest in the policy.

In the policy, the Beneficiary Designation


Indorsement states that the designation is
‘irrevocable’. This fact was never disproved by the
private respondent.

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