The Supreme Court ruled that biological parents can claim death benefits under the Employees’ Compensation Program (ECP) even if their child was legally adopted, especially when the adoptive parent dies during the child’s minority. This decision clarifies that biological parents’ rights are not entirely severed by adoption and can be restored in certain circumstances, ensuring that dependent parents are not unjustly excluded from receiving benefits intended to support them.

From Adoption to Loss: Can a Biological Mother Claim Death Benefits?

This case revolves around Bernardina Bartolome’s claim for death benefits after her biological son, John Colcol, died in a work-related accident. John had been legally adopted by his great-grandfather, Cornelio Colcol. The Social Security System (SSS) and the Employees’ Compensation Commission (ECC) denied Bernardina’s claim, asserting that the adoption terminated her rights as John’s parent. The legal question is whether Bernardina, as the biological mother of the deceased but legally adopted employee, is considered a secondary beneficiary entitled to receive benefits under the Employees’ Compensation Program (ECP).

The Supreme Court addressed this issue, noting that the ECC had overlooked critical evidence: Cornelio’s death certificate. The Court emphasized that administrative agencies’ factual findings are usually respected, but this deference is not absolute. In this case, Cornelio died less than three years after adopting John, a fact crucial to the outcome. This led the Court to examine the eligibility of biological parents for death benefits under the ECP, particularly concerning Article 167 (j) of the Labor Code.

Article 167 (j) of the Labor Code defines beneficiaries as:

‘Beneficiaries’ means the dependent spouse until he remarries and dependent children, who are the primary beneficiaries. In their absence, the dependent parents and subject to the restrictions imposed on dependent children, the illegitimate children and legitimate descendants who are the secondary beneficiaries; Provided, that the dependent acknowledged natural child shall be considered as a primary beneficiary when there are no other dependent children who are qualified and eligible for monthly income benefit.

The ECC’s implementing rules, specifically Rule XV of the Amended Rules on Employees’ Compensation, limited “dependent parents” to “legitimate parents.” The ECC argued that the adoption decree severed the relationship between John and Bernardina, disqualifying her as a secondary beneficiary. However, the Supreme Court disagreed, stating that Rule XV unduly restricted the Labor Code’s scope and engaged in unauthorized administrative legislation. The Court cited Article 7 of the Civil Code, emphasizing that administrative regulations must align with the law.

Administrative or executive acts, orders, and regulations shall be valid only when they are not contrary to the laws or the Constitution.

The Supreme Court found that the ECC’s interpretation deviated from the clear language of Article 167 (j) of the Labor Code. The Court referenced Diaz v. Intermediate Appellate Court, where the term “relatives” was broadly construed, noting that the term “parents” should also be taken in its general sense. Therefore, it includes all parents, whether legitimate or illegitimate, by nature or adoption. The Court underscored that the law does not distinguish, and neither should the implementing rules. The phrase “dependent parents” covers all parents who need support or assistance, regardless of their legal status.

Moreover, the Supreme Court pointed out that limiting parent beneficiaries to legitimate parents would violate the equal protection clause of the Constitution. By discriminating against illegitimate parents, the ECC’s rule failed the test of reasonableness. Equal protection requires that similarly situated individuals be treated alike, and there was no valid reason to differentiate between legitimate and illegitimate parents in this context. The Court held that there was no compelling basis to discriminate against illegitimate parents, as the classification was not germane to the law being implemented.

The Supreme Court noted that while parental authority is severed by adoption, the ties between the adoptee and biological parents are not entirely eliminated. The Court applied Section 20 of Republic Act No. 8552, the Domestic Adoption Act, by analogy. Although RA 8552 was enacted after Cornelio’s death, the principles behind it, especially the best interest of the child, justified the disposition. The biological parents may regain parental authority and legal custody if the adoptee is still a minor when the adoptive parents’ rights are terminated.

The biological parents, in some instances, can inherit from the adopted, which can be gleaned from Art. 190 of the Family Code:

Art. 190. Legal or intestate succession to the estate of the adopted shall be governed by the following rules:

(2) When the parents, legitimate or illegitimate, or the legitimate ascendants of the adopted concur with the adopter, they shall divide the entire estate, one-half to be inherited by the parents or ascendants and the other half, by the adopters;

At the time of Cornelio Colcol’s death, which was prior to the effectivity of the Family Code, the governing provision is Art. 984 of the New Civil Code, which provides:

Art. 984. In case of the death of an adopted child, leaving no children or descendants, his parents and relatives by consanguinity and not by adoption, shall be his legal heirs.

The Court emphasized that John’s adoptive father died when John was still a minor. Under such circumstance, parental authority should be deemed to have reverted in favor of the biological parents. Without such reversion, the child would be left without parental care.

FAQs

What was the key issue in this case?	The central issue was whether the biological mother of a deceased, legally adopted employee could claim death benefits under the Employees’ Compensation Program (ECP), given that the adoptive parent had also passed away.
Why did the SSS and ECC initially deny the claim?	The SSS and ECC denied the claim because John Colcol had been legally adopted, and they interpreted the law as prioritizing the adoptive parent as the beneficiary, thus terminating the rights of the biological mother.
What was the Supreme Court’s rationale for reversing the decision?	The Supreme Court reversed the decision, stating that the ECC had overlooked key evidence (the adoptive parent’s death) and that limiting parent beneficiaries to “legitimate parents” was an invalid restriction on the Labor Code.
How did the Court interpret the term “dependent parents” in the Labor Code?	The Court interpreted “dependent parents” broadly to include all parents—legitimate, illegitimate, biological, or adoptive—who are dependent on the employee for support, in line with the Labor Code’s intent.
What role did the adoptive parent’s death play in the Court’s decision?	The adoptive parent’s death was crucial because it occurred when John was still a minor, leading the Court to conclude that parental authority should revert to the biological mother to ensure John’s care.
Did the Court find any constitutional issues with the ECC’s interpretation?	Yes, the Court found that limiting death benefits to legitimate parents violated the equal protection clause by unfairly discriminating against illegitimate parents, without any reasonable basis.
What is the practical implication of this ruling for biological parents?	This ruling clarifies that biological parents are not entirely cut off from their children’s benefits after adoption, particularly if the adoptive parent dies during the child’s minority and the biological parent is dependent on the child.
How does this decision affect the Amended Rules on Employees’ Compensation?	The Court effectively struck down the phrase “illegitimate” in Rule XV, Section l(c)(l) of the Amended Rules, allowing illegitimate parents to claim death benefits.
What evidence supported the petitioner’s claim of dependency?	The petitioner presented evidence such as her SSS application, the death certificate, and the report of personal injury or loss of life that the deceased son had filed, showing that the mother had been declared as beneficiary and that they lived at the same residence.

In conclusion, the Supreme Court’s decision in Bartolome v. Social Security System reaffirms the rights of biological parents in specific adoption scenarios, ensuring that the Employees’ Compensation Program serves its purpose of providing adequate benefits to dependent family members. This ruling acknowledges the continuing ties between biological parents and their children, even after adoption, particularly when adoptive parents are no longer able to provide care.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Bernardina P. Bartolome vs. Social Security System and Scanmar Maritime Services, Inc., G.R. No. 192531, November 12, 2014