Del Val v.

Del Val (1915) – Beneficiary

 Petitioners and respondent are brothers and sisters and are the only heirs and next
of kin of Gregorio del Val who died intestate.
 Gregorio had taken out insurance on his life for 40k and made it payable to
respondent ANDRES DEL VAL as sole beneficiary.
 After Gregorio’s death, Andres collected the proceeds of the policy.
o Of the said policy, Andres paid around 18k to redeem some real properties
which Gregorio had sold to third persons during his lifetime.
o But said redemption of the properties was made by Andres’ lawyer in the
name of Andres and the petitioners.
o Accdg to Andres, said redemption in the name of Petitioners and himself was
without his knowledge and that since the redemption, petitioners have been
in possession of the property without paying taxes or making repairs
o Andres also took possession of most of Gregorio’s personal property, which
he still has in his possession, and that he has also the balance on said
insurance policy amounting to P21,634.80.
 Petitioners contend that the amount of the insurance policy belonged to the estate of
the deceased and not to the defendant personally; that, therefore, they are entitled to
a partition not only on the properties but also of the P40k life insurance.
 Andres claims that he is the sole owner of the proceeds and filed a counterclaim,
praying that he be declared:
o Sole owner of the real property, redeemed with the use of the insurance
proceeds and its remainder;
o Petitioners to account for the use and occupation of the premises.

Do the other heirs have a right to the insurance proceeds even though Andres
was named sole beneficiary? – No.

 Proceeds of an insurance policy belong exclusively to the beneficiary and not to the
estate of the person whose life was insured, and such proceeds are the separate
and individual property of the beneficiary, and not of the heirs of the person whose
life was insured
o section 428 of the Code of Commerce reads: “The amount which the
underwriter must deliver to the person insured, in fulfillment of the contract,
shall be the property of the latter, even against the claims of the legitimate
heirs or creditors of any kind whatsoever of the person who effected the
insurance in favor of the former.”
 Proceeds of a life insurance are not gifts or donations as governed by the Civil Code.
 The contract of life insurance is a special contract and the destination of the
proceeds thereof is determined by special laws which deal exclusively with that
subject. The Civil Code has no provisions which relate directly and specifically to life-
insurance contracts or to the destination of life insurance proceeds. That subject is
regulated exclusively by the Code of Commerce which provides for the terms of the
contract, the relations of the parties and the destination of the proceeds of the policy.
 The proceeds of the life insurance policy being the exclusive property of the
defendant and he having used a portion thereof in the repurchase of the real estate
sold by the decedent prior to his death with right to repurchase, it must still be proved
whether the intention of Andres was to redeem the property for the benefit of all the
heirs or of himself alone.
o Because of this, the case was remanded to the lower court to determine the
true intention of Andres in redeeming the property.