Background

The case arose from a dispute over the custody of insurance proceeds intended for a minor beneficiary. The deceased, Florentino Pilapil, had named his brother Francisco as the trustee for his daughter Millian's insurance benefits. However, Millian's mother, Melchora Cabanas, sought to obtain the proceeds, arguing that as the child's mother and guardian, she was entitled to administer the funds.

Facts

• 1. Florentino Pilapil (the deceased) had a child, Millian Pilapil, with Melchora Cabanas, a married woman.
• 2. Millian Pilapil was ten years old when the complaint was filed.
• 3. Florentino Pilapil insured himself and named his child as the beneficiary, with his brother Francisco Pilapil to act as trustee during her minority.
• 4. Upon Florentino's death, the insurance proceeds were paid to Francisco Pilapil.
• 5. Melchora Cabanas, with whom the child lives, filed a complaint seeking the delivery of the insurance proceeds.
• 6. Melchora Cabanas filed the bond required by the Civil Code.

Arguments of the Petitioners

• 1. As the mother and legal guardian of the minor beneficiary, Melchora Cabanas claimed she was entitled to administer the insurance proceeds.
• 2. She cited Articles 320 and 321 of the Civil Code to support her claim.
• 3. Cabanas argued that she had filed the necessary bond as required by law.

Arguments of the Respondents

• 1. Francisco Pilapil justified his claim to retain the insurance proceeds by invoking the terms of the insurance policy.
• 2. He argued that he was named as the trustee in the insurance policy by the deceased.

Issues

• 1. Who should be entrusted with the responsibility of acting as trustee for the insurance proceeds meant for the minor beneficiary?
• 2. Does the designation of a trustee in an insurance policy override the provisions of the Civil Code regarding parental authority and property administration?

Ruling

• 1. The Supreme Court affirmed the lower court's decision in favor of the mother, Melchora Cabanas.
• 2. The Court based its decision on the following rationale: a. Articles 320 and 321 of the Civil Code clearly state that the mother, in the absence of the father, is the legal administrator of the child's property. b. The welfare of the child is the paramount consideration in cases of this nature. c. It is reasonable to assume that a mother is more likely to provide better care and attention to the child than an uncle. d. The child is already living with the mother, which supports the natural order of things. e. The judiciary, as an agency of the State acting as parens patriae, must prioritize the best interest of the child. f. The constitutional mandate to strengthen the family as a basic social institution supports the decision to favor the mother.

Doctrines

• 1. Parens Patriae: The principle that the State has a duty to protect persons who are legally unable to act on their own behalf, particularly children.
• 2. Parental Authority: The rights and responsibilities of parents over their children and their children's property, as outlined in the Civil Code.
• 3. Statutory Interpretation: When the language of the law is clear and unambiguous, the court's duty is to apply the law, not interpret it.

Key Excerpts

• 1. "Where codal or statutory norms are cast in categorical language, the task before it is not one of interpretation but of application."
• 2. "What is paramount, as mentioned at the outset, is the welfare of the child."
• 3. "The judiciary pursuant to its role as an agency of the State as parens patriae, with an even greater stress on family unity under the present Constitution, did weigh in the balance the opposing claims and did come to the conclusion that the welfare of the child called for the mother to be entrusted with such responsibility."

Statutory and Constitutional Provisions

• 1. Article II, Section 4 of the 1973 Constitution: "The State shall strengthen the family as a basic social institution."