**Cabanas v. Pilapil, G.R. No. L-24384, August 1, 1974**
### Facts:
1. **Parties Involved:**
– **Plaintiff and Appellee:** Melchora Cabanas (Mother)
– **Defendant and Appellant:** Francisco Pilapil (Uncle)
2. **Context & Dispute:**
– The dispute is over who shall act as trustee for the proceeds of an insurance policy issued on the life of Florentino Pilapil, the father of minor Millian Pilapil.
– Florentino Pilapil named his brother Francisco Pilapil as the trustee for the insurance proceeds.
3. **Insurance Policy:**
– Upon Florentino Pilapil’s death, the proceeds of the insurance policy were paid to Francisco Pilapil, the designated trustee.
– Melchora Cabanas, the mother of the minor, filed a complaint demanding the delivery of the insurance proceeds to her, arguing she was the legal administrator of her daughter’s property.
4. **Lower Court Proceedings:**
– Melchora Cabanas argued her right based on Civil Code provisions Articles 320 and 321, stating that as the mother and legal administrator, she was entitled to administer the property, provided she gave the required bond.
– Francisco Pilapil contended that the insurance policy designated him as the trustee and hence he should administer the proceeds.
5. **Lower Court Decision:**
– The lower court ruled in favor of Melchora Cabanas, emphasizing that as per Articles 320 and 321 of the Civil Code, the mother was the legal administrator in the absence of the father and entitled to the proceeds upon providing the bond.
– The court found the trust provision of the insurance policy conflicting with statutory law to be pro tanto null and void.
6. **Appeal:**
– Francisco Pilapil challenged the lower court decision, maintaining his entitlement as per the insurance policy.
### Issues:
1. **Legal Administrator:**
– Whether the mother, Melchora Cabanas, is the rightful legal administrator of the minor’s property under Civil Code provisions, notwithstanding the trust stipulated in the insurance policy.
2. **Validity of the Trust:**
– Whether the trust provision designating Francisco Pilapil as trustee can supersede Civil Code provisions regarding parental authority and administration.
### Court’s Decision:
1. **Legal Administrator:**
– The Supreme Court affirmed that under Articles 320 and 321 of the Civil Code, the mother is indeed the legal administrator of the minor’s property in the absence of the father. These articles explicitly state that the father or the mother is the legal administrator of the child’s property.
2. **Invalidity of the Trust:**
– The trust provision in the insurance policy, to the extent it conflicted with the statutory mandate of Articles 320 and 321, was declared pro tanto null and void. The court held that statutory provisions, overwhelming in their clarity, must govern and the issuance of a bond ensures the child’s protection.
### Doctrine:
1. **Articles 320 and 321 of the Civil Code:**
– Article 320 establishes that the father, or in his absence, the mother, is the legal administrator of the property pertaining to the child under parental authority, subject to bond requirements for property worth over two thousand pesos.
– Article 321 asserts that properties acquired by an unemancipated child by any lucrative title belong to the child in ownership, but the father or mother has usufructuary rights if they have parental authority and the child lives with them.
### Class Notes:
1. **Parental Authority and Administration (Civil Code Articles 320 and 321):**
– **Key Principles:**
– Parents, as legal administrators, manage the minor’s property.
– Trust provisions conflicting statutory parental rights are null.
– Bond requirements safeguard the minor’s interest.
– **Application:**
– Favors natural parents over other relatives for child’s affected property.
– Reinforces the judiciary’s role as parens patriae, prioritizing child welfare.
– Upholds constitutional protections of family unity and parental rights.
### Historical Background:
The case hinges on the legal doctrine of parental authority, entrenched in traditional and statutory philippine laws. This principle establishes that parents hold a natural and judicially supported precedence in matters concerning their children’s welfare and property administration. The decision reaffirms the State’s role as a protector of minor’s interests, reflecting deep cultural and legal underpinnings that view family cohesion as paramount. This case exemplifies the judiciary’s enduring commitment to these foundational principles.
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