Facts

Around October 2003, Zenaida Posadas ("decedent"), applied for a $500,000 life insurance policy with American General Life Insurance Company ("AGL") naming her six siblings as equal beneficiaries. On Feb. 5, 2015, decedent submitted a Change of Beneficiary form naming one sibling, Rolando Posadas ("Cross-Claimant"), as the 100% primary beneficiary, and two of decedent's nephews, Michael Ryan Posadas and Allen Ray Posadas, each as 50% contingent beneficiaries.

On Oct. 30, 2020, decedent died, causing the policy's death benefit to become due and payable. On Sept. 1, 2021, counsel for Shirley, Jorge, Fabian, Bernardo, and Franklin Posadas ("Cross-Defendants") sent a letter to AGL contesting the validity of the 2015 Change of Beneficiary form. On Jan. 28, 2022, Cross-Claimant submitted his claim to AGL for the policy proceeds.

In response, AGL filed a complaint for interpleader relief and deposited the funds with the District Court in the Central District of California. Rolando Posadas filed a counter-claim against the five other surviving siblings for declaratory relief seeking a judicial finding that he is indeed the beneficiary of the life insurance policy and is entitled to 100% of the proceeds based on the 2015 Change of Beneficiary form.

CROSS-COMPLAINANT CONTENTIONS: Cross-Claimant contended he was entitled to 100% of the policy proceeds based on the Feb. 5, 2015 change of beneficiary form and there was no evidence to suggest that the 2015 change of beneficiary form did not reflect decedent's true intentions.

CROSS-DEFENDANT CONTENTIONS: Cross-Defendants alleged Rolando exerted undue influence or fraud over decedent to be named the sole beneficiary in the 2015 change of beneficiary form. Cross-Defendants speculated in their claim that a confidential relationship must have existed when decedent enlisted the help of Cross-Claimant to build a house in the Philippines. Cross-Defendants further asserted Rolando is not the intended beneficiary because following the death of the decedent, he did not act as a responsible party regarding funeral arrangements.

Result

On Cross-Claimant's motion for summary judgment, the court found that Cross-Defendants' assertions of undue influence were merely speculation and Cross-Defendants presented no evidence that the 2015 Change of Beneficiary form did not reflect Decedent's wishes. The court granted Cross-Claimant's motion for summary judgment without oral argument. Judgment was entered in favor of Cross-Claimant for 100% of the $500,000 policy proceeds.