G.R. No. L-54216 July 19, 1989
Lessons Applicable: Irrevocable Designation (Insurance)
FACTS:
- January 15, 1968: Rodolfo c. Dimayuga acquired a life insurance from Philippine American Insurance Company and designated his wife and six minor children as irrevocable beneficiaries
- February 22, 1980: Rodolfo c. Dimayuga filed with the CFI to amend the designation of the beneficiaries in his life policy from irrevocable to revocable
- CFI: change the policy to revocable
ISSUE: W/N Rodolfo can change his policy to revocable
HELD: NO. Set Aside
- inasmuch as the designation of the primary/contingent beneficiary/beneficiaries in this Policy has been made without reserving the right to change said beneficiary/ beneficiaries, such designation may not be surrendered to the Company, released or assigned; and no right or privilege under the Policy may be exercised, or agreement made with the Company to any change in or amendment to the Policy, without the consent of the said beneficiary/beneficiaries
- it is only with the consent of all the beneficiaries that any change or amendment in the policy concerning the irrevocable beneficiaries may be legally and validly effected
- parent-insured cannot exercise rights and/or privileges pertaining to the insurance contract, for otherwise, the vested rights of the irrevocable beneficiaries would be rendered inconsequential
