6th Batch- Insurance Cases

8/10/2019 6th Batch- Insurance Cases

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LOSS

United Merchants Corporation vs. Country Bankers Insurance Corporation

FACTS:

1. Petitioner United Merchants Corporation (UMC) is engaged in thebusiness of buying, selling and manufacturing Christmas lights.

2. UMC‘s General Manager Alfredo Tan insured UMC‘s stocks in trade ofChristmas lights against fire with defendant Country Bankers InsuranceCorporation (CBIC) for P15000000.00

3. On 7 May 1996, UMC and CBIC executed Endorsement and Fire Invoiceto form part of the Insurance Policy. Endorsement provides that UMC‘sstocks in trade were insured against additional perils, to wit: ―typhoon,flood, ext. cover and full earthquake.‖ The sum insured was also increasedto P50000000.00

4. On july 3, 1996, a fire gutted the warehouse rented by UMC. CBICdesignated CRM Adjustment Corporation (CRM) to investigate andevaluate UMC‘s loss by reason of the fire. CBIC reinsurer, Central Surety,likewise requested the National Bureau of Investigation (NBI) to conduct aparallel investigation.

5. UMC submitted to CBIC its sworn statement of formal claim, with proofs ofits loss.

6. UMC demanded for at least 50% payment of its claim from CBIC. UMCreceived CBIC‘s letter, rejecting UMC‘s claim due to breach of Conditionno. 15 of the Insurance Policy. (if the claim be in any respect fraudulent,or if the loss or damaged be occasioned by the willful act, or with the

connivance of the insured, all the benefits under this Policy shall beforfeited.‖

7. UMC filed a complaint against CBIC with the RTC of manila. UMCanchored its insurance claim on the Insurance Policy, the sworn statementof formal claim earlier submitted, and the certification made by Deputy FireChief/ Senior superintendent of the Bureau of Fire Protection.

8. The bureau further certifies that no evidence was gathered to prove thatthe establishment was willfully feloniously and intentionally set on fire.

9. CBIC admitted the issuance of the Insurance Policy to UMC but raised thedefense that UMC‘s claim was fraudulent because UMC‘s statement ofinventory showed that it had no stocks in trade as of 31 december 1995,

and that UMC‘s suspicious purchases for the year 1996 did not evenamount to 25000000.00. UMC‘s GIS and Financial Reports furtherrevealed that it had insufficient capital, which meant UMC could not affordthe alleged P50,000.000.00 worth of stocks in trade.

10. UMC claimed that it did not make any false declaration because theinvoices were genuine and the statement of inventory was for internalrevenue purposes only, not for its insurance claim.



11. UMC‘s disbursing of ficer testified that UMC had no importation for theyear 1996 because it bought from its local suppliers, one of which is Fuzeindustries Manufacturer Philippines.

ISSUE: Is the insurer liable

RULING:

ARSON- insurer failed to proveFRAUDULENT- insurer was able to prove

ARSON:1. Burden of proof is the duty of any party to present evidence to establish

his claim or defense by the amount fo evidence required by law, which ispreponderance of evidence in civil cases. The party, whether plaintiff ordefendant, who asserts the affirmative of the issue has the burden of proof

to obtain a favorable judgment. Particularly, in insurance cases, once aninsured makes out a prima facie case in its favor, the burden of evidenceshifts to the insurer to controvert the insured‘s prima facie case. In thepresent case, UMC established a prima facie case against CBIC.

2. An insurer who seeks to defeat a cliam because of an exception orlimitation in the policy has the burden of establishing that the loss comeswithin the purview of the exception or limitation. If loss is provedapparently within a contract of insurance, the burden is upon the insurer toestablish that the loss arose from a couse which limits its liability. In thepresent case, CBIC failed to discharge its primordial burden ofestablishing that the damage or loss was caused by arson, a limitation inthe policy.

FRAUDULENT: (di to masyadong related sa topic na loss, pero dito kasipinakita kung pano nanalo yung insurer sa case. Na prove ng insurer yungfraud dun sa claim nung insured. Sabi ng insured mga P50,000,000.00 dawyung cost nung stock in trade pero ang totoo hindi aabot sa P50,000,000.00 )1. Insurer found out that there was no Fuze Industries Manufacturer Phils.

Located at 55 Mahinhin st., teacher‘s village, quezon City. 2. The sworn statement in formal calim submitted by the insured includes: a.)

letters of credit and invoices for raw materials, Christmas lights andcartons purchased, b.) charges for assembling Christmas lights, c.)delivery receipts of Christmas lights. In this case, only the letters of creditand invoices for raw materials, Christmas lights and cartons purchasedmay be consider ed in the term ―stocks in trade‖

3. Fraudulent discrepancy between the actual loss and that claimed in theproof of loss avoids the contract.

4. The amount in UMC‘s Income Statement or financial reports is twenty-fivetimes the claim UMC seeks to enforce.



COUNTRY BANKERS INSURANCE CORPORATION vs. LIANGA BAY ANDCOMMUNITY MULTI-PURPOSE COOPERATIVE, INC.

Facts:

* Petitioner Country Bankers Insurance Corp insured respondent Lianga Bay andCommunity‘s stocks-in-trade against fire loss, damage or liability during theperiod starting from June 20, 1989 at 4:00 p.m. to June 20, 1990 at 4:00 p.m., forthe sum of Two Hundred Thousand Pesos (P200,000.00).

* On July 1, 1989, respondent‘s building located at Lianga, Surigao del Sur wasgutted by fire and reduced to ashes, resulting in the total loss of the respondent‘sstocks-in-trade, pieces of furnitures and fixtures, equipments and records.Hence, the respondent filed an insurance claim with the petitioner.

* Country Bankers, however, denied the insurance claim on the ground that,

based on the documents submitted by respondent, the building was set on fire bytwo (2) NPA rebels who wanted to obtain canned goods, rice and medicines asprovisions for their comrades in the forest, which is an excepted risk under thepolicy conditions of Fire Insurance Policy which provides:

―This insurance does not cover any loss or damage occasioned by or through orin consequence, directly or indirectly, of any of the following occurrences,namely: Mutiny, riot, military or popular uprising, insurrection, rebellion,revolution, military or usurped power.‖

* Respondent instituted the complaint for recovery of ―loss, damage or liability‖

against petitioner before the trial court. The petitioner answered the complaintand reiterated that the loss was due to NPA rebels, an excepted risk under thefire insurance policy.

* Trial Court rendered its decision in favor of respondent and was affirmed in totoby CA. Hence, this petition.

Issue: Whether or not country bankers is liable.

Held: Yes.

* The petitioner does not dispute that the respondent‘s stocks-in-trade wereinsured against fire loss, damage or liability under its Fire Insurance Policy andthat the respondent lost its stocks-in-trade in a fire that occurred on July 1, 1989,within the duration of said fire insurance.

* As regards respondent‘s contention that the cause of the loss was an exceptedrisk under the terms of the policy, SC explained that where a risk is excepted bythe terms of a policy which insures against other perils or hazards, loss from



such a risk constitutes a defense which the insurer may urge, since it has notassumed that risk, and from this it follows that an insurer seeking to defeat aclaim because of an exception or limitation in the policy has the burden ofproving that the loss comes within the purview of the exception or limitation setup. If a proof is made of a loss apparently within a contract of insurance, the

burden is upon the insurer to prove that the loss arose from a cause of losswhich is excepted or for which it is not liable, or from a cause which limits itsliability.

* Since the petitioner in this case is defending on the ground of non-coverageand relying upon an exception clause in policy, it has the burden of proving thefacts upon which such excepted risk is based, by a preponderance of evidence.But petitioner failed to do so.

* The petitioner merely relies on the Sworn Statements of witnesses that thosearmed men wanted to get canned goods and rice for their consumption in the

forest and that PD investigation further disclosed that the perpetrators aremembers of the NPA. Additionally, the Spot Report of Pfc. Arturo Juarbal relativeto the statement of the witness to the effect that NPA rebels allegedly set fire tothe respondent‘s building is inadmissible in evidence, for the purpose of provingthe truth of the statements contained in the said report, for being hearsay. Thereport was based on the personal knowledge of the caretaker Jose Lomocso whowitnessed every single incident surrounding the facts and circumstances of thecase. No investigation, independent of the statements gathered from JoseLomocso, was conducted by Pfc. Arturo V. Juarbal.

FGU Insurance Corporation vs CA

Facts:

ANCO Enterprises Company (ANCO), a partnership between Ang Gui and CoTo, was engaged in the shipping business. It owned 1 tugboat and 1 barge.Since the barge had no engine of its own, it needed to be towed by a tugboat forit to move from one place to another.

San Miguel Corporation (SMC) shipped from Mandaue City, Cebu, on board thebarge for towage cases of beer; one for shipment to Antique and another to Iloilo.

The barge carrying the cases of beer was towed all the way from Mandaue Cityto Antique. The tugboat left the barge immediately after reaching Antique.

When the vessels arrived at Antique, the clouds over the sea were dark and thewaves were already big. The workers unloading the cargoes of SMC on boardthe barge began to complain about their difficulty in unloading the cargoes. SMC,thru its districts sales supervisor, requested ANCO to transfer the barge to asafer place because the vessel might not withstand the big waves. The request



was ignored by ANCO bcos he was confident that the barge could withstand thewaves. With the waves growing bigger, only 10,790 cases of beer weredischarged to the unloaders, leaving behind 29,210.

That evening the barge crew abandoned the vessel because the barge's rope

attached to the wharf was cut off by the waves. Soon after, the barge runaground and was broken and the cargoes of beer in the barge were swept away.

SMC filed a complaint for Breach of Contract of Carriage and Damages against ANCO.

Upon Ang Gui's death, the ANCO partnership was dissolved hence, SMC filed asecond amended complaint which was admitted by the Court impleading thesurviving partner, Co To and the Estate of Ang Gui represented by Lucio, Julianand Jaime, all surnamed Ang. The substituted defendants adopted the originalanswer with counterclaim of ANCO ―since the substantial allegations of the

or iginal complaint and the amended complaint are practically the same.‖

ANCO claimed that it had an agreement with SMC that ANCO would not be liablefor any losses or damages resulting to the cargoes by reason of fortuitous event.

ANCO further asserted that there was an agreement between them and SMC toinsure the cargoes in order to recover indemnity in case of loss. Pursuant to thatagreement, the cargoes to the extent of Twenty Thousand (20,000) cases wasinsured with FGU Insurance Corporation (FGU) for the total amount of EightHundred Fifty-Eight Thousand Five Hundred Pesos (P858,500.00) per MarineInsurance Policy No. 29591.

According to ANCO, the loss of said cargoes occurred as a result of risks insuredagainst in the insurance policy and during the existence and lifetime of saidinsurance policy. ANCO went on to assert that in the remote possibility that thecourt will order ANCO to pay SMC‘s claim, the third-party defendant corporationshould be held liable to indemnify or reimburse ANCO whatever amounts, ordamages, it may be required to pay to SMC.

FGU admitted the existence of the Insurance Policy under Marine Cover NoteNo. 29591 but maintained that the alleged loss of the cargoes covered by thesaid insurance policy cannot be attributed directly or indirectly to any of the risksinsured against in the said insurance policy. According to FGU, it is only liableunder the policy to Third-party Plaintiff ANCO and/or Plaintiff SMC in case of anyof the following:

a) total loss of the entire shipment;

b) loss of any case as a result of the sinking of the vessel; or

c) loss as a result of the vessel being on fire.



Furthermore, FGU alleged that the Third-Party Plaintiff ANCO and Plaintiff SMCfailed to exercise ordinary diligence or the diligence of a good father of the familyin the care and supervision of the cargoes insured to prevent its loss and/ordestruction.

TRIAL COURT: The trial court found that while the cargoes were indeed lost dueto fortuitous event, there was failure on ANCO‘s part, through theirrepresentatives, to observe the degree of diligence required that would exoneratethem from liability. The trial court thus held the Estate of Ang Gui and Co Toliable to SMC for the amount of the lost shipment. With respect to FGU, the courta quo found FGU liable to bear Fifty-Three Percent (53%) of the amount of thelost cargoes.

ISSUE: Whether or not FGU can be held liable under the insurance policy toreimburse ANCO for the loss of the cargoes

RULING:

A careful study of the records shows no cogent reason to fault the findings of thelower court, as sustained by the appellate court, that ANCO‘s representativesfailed to exercise the extraordinary degree of diligence required by the law toexculpate them from liability for the loss of the cargoes.

It is borne out in the testimony of the witnesses on record that the barge had noengine of its own and could not maneuver by itself. Yet, the patron of ANCO‘stugboat left it to fend for itself notwithstanding the fact that as the two vesselsarrived at the port of Antique, signs of the impending storm were already

manifest. Had the patron or captain of the tugboat, the representative of thedefendants observed extraordinary diligence in placing the barge in a safe place,the loss to the cargo of the plaintiff could not have occurred. In short, therefore,defendants through their representatives, failed to observe the degree ofdiligence required of them under the provision of Art. 1733 of the Civil Code ofthe Philippines.

ANCO‘s arguments boil down to the claim that the loss of the cargoes wascaused by the typhoon Sisang, a fortuitous event (caso fortuito), and there wasno fault or negligence on their part. In fact, ANCO claims that their crewmembersexercised due diligence to prevent or minimize the loss of the cargoes but theirefforts proved no match to the forces unleashed by the typhoon which, inpetitioners‘ own words was, by any yardstick, a natural calamity, a fortuitousevent, an act of God, the consequences of which petitioners could not be heldliable for.

The Civil Code provides:



Art. 1733. Common carriers, from the nature of their business and for reasons ofpublic policy are bound to observe extraordinary diligence in the vigilance overthe goods and for the safety of the passengers transported by them, according toall the circumstances of each case.

Such extraordinary diligence in vigilance over the goods is further expressed in Articles 1734, 1735, and 1745 Nos. 5, 6, and 7 . . .

Art. 1734. Common carriers are responsible for the loss, destruction, ordeterioration of the goods, unless the same is due to any of the following causesonly:

(1) Flood, storm, earthquake, lightning, or other natural disaster or calamity;

Art. 1739. In order that the common carrier may be exempted from responsibility,the natural disaster must have been the proximate and only cause of the loss.

However, the common carrier must exercise due diligence to prevent or minimizeloss before, during and after the occurrence of flood, storm, or other naturaldisaster in order that the common carrier may be exempted from liability for theloss, destruction, or deterioration of the goods . . .

Caso fortuito or force majeure (which in law are identical insofar as they exemptan obligor from liability) by definition, are extraordinary events not foreseeable oravoidable, events that could not be foreseen, or which though foreseen, wereinevitable. It is therefore not enough that the event should not have beenforeseen or anticipated, as is commonly believed but it must be one impossible toforesee or to avoid.

In this case, the calamity which caused the loss of the cargoes was notunforeseen nor was it unavoidable. In fact, the other vessels in the port of

Antique, managed to transfer to another place, a circumstance which promptedSMC‘s District Sales Supervisor to request that the barge be likewise transferred,but to no avail. The barge had no engine and could not maneuver by itself. Evenif ANCO‘s representatives wanted to transfer it, they no longer had any means todo so as the tugboat had already departed, leaving the barge to its own devices.The captain of the tugboat should have had the foresight not to leave the bargealone considering the pending storm.

While the loss of the cargoes was admittedly caused by the typhoon Sisang, anatural disaster, ANCO could not escape liability to respondent SMC. Therecords clearly show the failure of petitioners‘ representatives to exercise theextraordinary degree of diligence mandated by law. To be exempted fromresponsibility, the natural disaster should have been the proximate and onlycause of the loss. There must have been no contributory negligence on the partof the common carrier.



Therefore, as correctly pointed out by the appellate court, there was blatantnegligence on the part of the tugboat‘s crewmembers, first in leaving the engine-less barge at the mercy of the storm without the assistance of the tugboat, andagain in failing to heed the request of SMC‘s representatives to have the bargetransferred to a safer place, as was done by the other vessels in the port; thus,

making said blatant negligence the proximate cause of the loss of the cargoes.

One of the purposes for taking out insurance is to protect the insured against theconsequences of his own negligence and that of his agents. Thus, it is a basicrule in insurance that the carelessness and negligence of the insured or hisagents constitute no defense on the part of the insurer. This rule howeverpresupposes that the loss has occurred due to causes which could not havebeen prevented by the insured, despite the exercise of due diligence.

The question now is whether there is a certain degree of negligence on the partof the insured or his agents that will deprive him the right to recover under the

insurance contract. We say there is. However, to what extent such negligencemust go in order to exonerate the insurer from liability must be evaluated in lightof the circumstances surrounding each case. When evidence show that theinsured‘s negligence or recklessness is so gross as to be sufficient to constitute awillful act, the insurer must be exonerated.

Taking into account the circumstances present in the instant case, the courtconcludes that the blatant negligence of ANCO‘s employees is of such grosscharacter that it amounts to a wrongful act which must EXONERATE FGU fromliability under the insurance contract.

SUN INSURANCE OFFICE, LTD. vs. COURT OF APPEALS and NERISSALIM

G.R. No. 92383 July 17, 1992

FACTS: Sun Insurance issued a personal accident policy to Felix Lim, Jr. with aface value of P200,00. Two months later, he was dead with a bullet wound in hishead. As beneficiary, his wife Nerissa Lim sought payment on the policy but herclaim was rejected. Sun Insurance agreed that there was no suicide but alsoargued that there was no accident.

According to Pilar Nalagon, Lim‘s secretary, on October 6, 1982 at about 10 inthe evening, after his mother's birthday party, Lim was in a happy mood (but notdrunk) and was playing with his handgun, from which he had previously removedthe magazine. As she watched television, he stood in front of her and pointed thegun at her. She pushed it aside and said it might he loaded. He assured her itwas not and then pointed it to his temple. The next moment there was anexplosion and Lim slumped to the floor. He was dead before he fell.



ISSUE: Whether or not Sun Insurance is liable to the beneficiary for the facevalue of the insurance contract

Petitioner‘s contention: 1) There is no accident when a deliberate act isperformed unless some additional, unexpected, independent and unforeseen

happening occurs which produces or brings about their injury or death."

2) The case falls under one of the four exceptions: ―i) The insured personattempting to commit suicide wilfully exposing himself to needless peril except inan attempt to save human life. Lim, by pointing the gun to his temple wilfullyexposed himself to needless peril and so came under the exception.

HELD: Yes. The Court is convinced that the incident that resulted in Lim's deathwas indeed an accident. The term ―accident‖ was construed and consideredaccording to the ordinary understanding and common usage, to wit: that whichhappens by chance or fortuitously, without intention or design, and which is

unexpected, unusual, and unforeseen. The parties agree that Lim did not commitsuicide. As the secretary testified, Lim had removed the magazine from the gunand believed it was no longer dangerous. He expressly assured her that the gunwas not loaded. It is submitted that Lim did not willfully expose himself toneedless peril when he pointed the gun to his temple because the fact is that hethought it was not unsafe to do so. The act was precisely intended to assureNalagon that the gun was indeed harmless.

Lim was unquestionably negligent and that negligence cost him his own life. Butit should not prevent his widow from recovering from the insurance policy heobtained precisely against accident. There is nothing in the policy that relieves

the insurer of the responsibility to pay the indemnity agreed upon if the insured isshown to have contributed to his own accident. Indeed, most accidents arecaused by negligence. There are only four exceptions expressly made in thecontract to relieve the insurer from liability, and none of these exceptions isapplicable in the case at bar.

Therefore, the petition is liable to the private respondent in the sum ofP200,000.00 representing the face value of the insurance contract, with interestat the legal rate from the date of the filing of the complaint until the full amount ispaid.

NOTICE OF LOSSPACIFIC TIMBER EXPORT CORPORATION, petitioner,vs.THE HONORABLE COURT OF APPEALS and WORKMEN'S INSURANCECOMPANY, INC., respondents.



DE CASTRO, ** J.:

Facts:

On March 19, l963, the plaintiff secured temporary insurance from the defendantfor its exportation of 1,250,000 board feet of Philippine Lauan and Apitong logs tobe shipped from the Diapitan. Bay, Quezon Province to Okinawa and Tokyo,Japan. The defendant issued on said date Cover Note No. 1010, insuring thesaid cargo of the plaintiff.

The regular marine cargo policies were issued by the defendant in favor of theplaintiff on April 2, 1963. The two marine policies bore the numbers 53 HO 1032and 53 HO 1033 (Exhibits B and C, respectively). Policy No. 53 H0 1033 (ExhibitB) was for 542 pieces of logs equivalent to 499,950 board feet. Policy No. 53 H01033 was for 853 pieces of logs equivalent to 695,548 board feet (Exhibit C). The

total cargo insured under the two marine policies accordingly consisted of 1,395logs, or the equivalent of 1,195.498 bd. ft.

After the issuance of Cover Note No. 1010 (Exhibit A), but before the issuance ofthe two marine policies Nos. 53 HO 1032 and 53 HO 1033, some of the logsintended to be exported were lost during loading operations in the Diapitan Bay.

In a letter dated April 4, 1963, the plaintiff informed the defendant about the lossof 'appropriately 32 pieces of log's during loading of the 'SS Woodlock'.

Although dated April 4, 1963, the letter was received in the office of thedefendant only on April 15, 1963, as shown by the stamp impression appearingon the left bottom corner of said letter. In the report submitted by First Philippine

Adjustment Corporation, the adjuster found that 'the loss of 30 pieces of logs isnot covered by Policies Nos. 53 HO 1032 and 1033 inasmuch as said policiescovered the actual number of logs loaded on board the 'SS Woodlock' However,the loss of 30 pieces of logs is within the 1,250,000 bd. ft. covered by Cover Note1010 insured for $70,000.00.

On January 13, 1964, the defendant wrote the plaintiff denying the latter's claim,on the ground they defendant's investigation revealed that the entire shipment oflogs covered by the two marines policies No. 53 110 1032 and 713 HO 1033were received in good order at their point of destination. It was further stated thatthe said loss may not be considered as covered under Cover Note No. 1010because the said Note had become 'null and void by virtue of the issuance ofMarine Policy Nos. 53 HO 1032 and 1033.

Issue:Whether or not the Insurance company was absolved from responsibility due tounreasonable delay in giving notice of loss.



Held:No.

The defense of delay as raised by private respondent in resisting the claim

cannot be sustained. The law requires this ground of delay to be promptly andspecifically asserted when a claim on the insurance agreement is made. Theundisputed facts show that instead of invoking the ground of delay in objecting topetitioner's claim of recovery on the cover note, it took steps clearly indicativethat this particular ground for objection to the claim was never in its mind.

As already stated earlier, private respondent's reaction upon receipt of the noticeof loss, which was on April 15, 1963, was to set in motion from July 1963 whatwould be necessary to determine the cause and extent of the loss, with a view tothe payment thereof on the insurance agreement. Thus it sent its adjuster toinvestigate and assess the loss in July, 1963. The adjuster submitted his report

on August 23, 1963 and its computation of respondent's liability on September14, 1963. From April 1963 to July, 1963, enough time was available for privaterespondent to determine if petitioner was guilty of delay in communicating theloss to respondent company. In the proceedings that took place later in the Officeof the Insurance Commissioner, private respondent should then have raised thisground of delay to avoid liability. It did not do so. It must be because it did notfind any delay, as this Court fails to find a real and substantial sign thereof. Buteven on the assumption that there was delay, this Court is satisfied andconvinced that as expressly provided by law, waiver can successfully be raisedagainst private respondent. Thus Section 84 of the Insurance Act provides:

Section 84.—Delay in the presentation to an insurer of notice or proof of loss iswaived if caused by any act of his or if he omits to take objection promptly andspecifically upon that ground.

From what has been said, We find duly substantiated petitioner's assignments oferror.

MALAYAN INSURANCE CO. VS. CRUZ ARNALDO FACTS:On June 7, 1981, the petitioner (hereinafter called (MICO) issued to the privaterespondent, Coronacion Pinca, Fire Insurance Policy No. F-001-17212 on herproperty for the amount of P14,000.00 effective July 22, 1981, until July 22,1982.

On October 15,1981, MICO allegedly cancelled the policy for non-payment, ofthe premium and sent the corresponding notice to Pinca.

On December 24, 1981, payment of the premium for Pinca was received byDomingo Adora, agent of MICO.



On January 15, 1982, Adora remitted this payment to MICO,together with otherpayments.

On January 18, 1982, Pinca's property was completely burned.

On February 5, 1982, Pinca's payment was returned by MICO to Adora on theground that her policy had been cancelled earlier. But Adora refused to accept it.

In due time, Pinca made the requisite demands for payment, which MICOrejected. She then went to the Insurance Commission. It is because she wasultimately sustained by the public respondent that the petitioner appealed.

ISSUE: W/N MICO should be liable because its agent Adora was authorized toreceive it

HELD: YES. On these basis:

SEC. 77. An insurer is entitled to payment of the premium as soon as the thing isexposed to the peril insured against. Notwithstanding any agreement to thecontrary, no policy or contract of insurance issued by an insurance company isvalid and binding unless and until the premium thereof has been paid, except inthe case of a life or an industrial life policy whenever the grace period provisionapplies.

SEC. 306. xxx xxx xxx

Any insurance company which delivers to an insurance agant or insurancebroker a policy or contract of insurance shall be demmed to have authorizedsuch agent or broker to receive on its behalf payment of any premium which isdue on such policy or contract of insurance at the time of its issuance or deliveryor which becomes due thereon.Payment to an agent having authority to receive or collect payment is equivalentto payment to the principal himself; such payment is complete when the moneydelivered is into the agent's hands and is a discharge of the indebtedness owingto the principal.

SEC. 64. No policy of insurance other than life shall be cancelled by the insurerexcept upon prior notice thereof to the insured, and no notice of cancellation shallbe effective unless it is based on the occurrence, after the effective date of thepolicy, of one or more of the following:

(a) non-payment of premium;

(b) conviction of a crime arising out of acts increasing the hazard insured against;



(c) discovery of fraud or material misrepresentation;

(d) discovery of willful, or reckless acts or commissions increasing the hazardinsured against;

(e) physical changes in the property insured which result in the propertybecoming uninsurable;or

(f) a determination by the Commissioner that the continuation of the policy wouldviolate or would place the insurer in violation of this Code.

As for the method of cancellation, Section 65 provides as follows:

SEC. 65. All notices of cancellation mentioned in the preceding section shall bein writing, mailed or delivered to the named insured at the address shown in thepolicy, and shall state (a) which of the grounds set forth in section sixty-four is

relied upon and (b) that, upon written request of the named insured, the insurerwill furnish the facts on which the cancellation is based. A valid cancellation must, therefore, require concurrence of the followingconditions:

(1) There must be prior notice of cancellation to the insured;

(2) The notice must be based on the occurrence, after the effective date of thepolicy, of one or more of the grounds mentioned;

(3) The notice must be (a) in writing, (b) mailed, or delivered to the namedinsured, (c) at the address shown in the policy;

(4) It must state (a) which of the grounds mentioned in Section 64 is relied uponand (b) that upon written request of the insured, the insurer will furnish the factson which the cancellation is based.

All MICO's offers to show that the cancellation was communicated to the insuredis its employee's testimony that the said cancellation was sent "by mail throughour mailing section."

It stands to reason that if Pinca had really received the said notice, she would nothave made payment on the original policy on December 24, 1981. Instead, shewould have asked for a new insurance, effective on that date and until one yearlater, and so taken advantage of the extended period.

Incidentally, Adora had not been informed of the cancellation either and saw noreason not to accept the said payment.

Although Pinca's payment was remitted to MICO's by its agent on January 15,



1982, MICO sought to return it to Adora only on February 5, 1982, after itpresumably had learned of the occurrence of the loss insured against on January18, 1982 make the motives of MICO highly suspicious. Thus, the petition isdenied.

DOUBLE INSURANCE

GenIn And surety Corp vs Ng Hua (GR No. L-14373 January 30, 1960)

GENERAL INSURANCE AND SURETY CORPORATION, petitioner

NG HUA, respondent

Ponente:BENGZON, J.

FACTS:

April 15, 1952 – defendant General Insurance and Surety Corp issued fireinsurance Policy No. 471, for one year, the stock in trade of the Central PomadeFactory owned by Ng Hua, the court insured. Next day, the factory buildingburned, destroying insured properties.

Ng Hua claimed indemnity from the insurer. Policy covered damages up toP10,000.00; but after negotiations and upon suggestion of the Manila AdjustmentCompany, he reduced the claim of P5,000.00.

Defendant insurer refused to pay:

(a) action was not filed in time;

(b) violation of warranty;

(c) submission of fraudulent claim; and

(d) failure to pay the premium.

The aforesaid Policy No. 471 contains this stipulation on the back thereof;

3. The insured shall give notice to the company of any insurance or insurancesalready affected, or which may subsequently be effected, covering any of theproperty hereby insured, and unless such notice be given and the particulars ofsuch insurance or insurances be stated in or endorsed on this Policy by or onbehalf of the Company before the occurrence of any loss or damage, all benefitsunder the policy shall be forfeited.



The face of the policy bore the annotation: "Co-Insurance Declared —NIL"

Ng Hua had obtained fire insurance on same goods, for same period, in theamount of P20,000.00 from General Indemnity Co. However, the CA held thatthere was no violation of the above clause, inasmuch as "co-insurance exists

when a condition of the policy requires the insured to bear ratable proportion ofthe loss when the value of the insured property exceeds the face value of thepolicy," hence there is no co-insurance here.

ISSUE:

Whether there was a breach of warranty thus insurer can rescind

RULING:

Discussion — Undoubtedly, co-insurance exists under the condition described by

the appellate court. But that is one kind of co-insurance. It is not the only situationwhere co-insurance exists. Other insurers of the same property against the samehazard are sometimes referred as co-insurers and the ensuing combination asco-insurance. And considering the terms of the policy which required the insuredto declare other insurances, the statement in question must be deemed to be astatement (warranty) binding on both insurer and insured, that there were noother insurance on the property. Remember it runs "Co-Insurance declared";emphasis on the last word. If "Co-Insurance" means that CA says, the annotationserved no purpose. It would even be contrary to the policy itself, which in itsclause No. 17 made the insured a co-insurer for the excess of the value of theproperty over the amount of the policy.

The annotation then, must be deemed to be a warranty that the property was notinsured by any other policy. Violation thereof entitles the insurer to rescind.(Sec69 Insurance Act) The materiality of non-disclosure of other insurancepolicies is not open to doubt.

Furthermore, even if the annotations were overlooked, the defendant insurerwould still be free from liability because there is no question that the policy issuedby General Indemnity had not been stated in nor endorsed on Policy No. 471 ofdefendant. And as stipulated in the above-quoted provisions of such policy "allbenefit under this policy shall be forfeited."

Ng Hua alleges "actual knowledge" on the part of General insurance. He doesnot say when such knowledge was acquired or imparted. If General Insuranceknow before issuing its policy or before the fire, such knowledge might overcomethe insurer's defense. However, CA found no evidence of such knowledge.



Defendant insurer successfully established its defense of warranty breach orconcealment of the other insurance and/or violation of the provision of the policyabove-mentioned.

*Insurer acquitted from all the liability under the policy.

REINSURANCE

THE PHILIPPINE AMERICAN LIFE INSURANCE COMPANY vs. THEAUDITOR GENERAL

APPLICABLE LAW :

Section 3, Margin Law

exemption of the following obligations from payment of the margin fee:

1. liquidation of drafts drawn under letters of credit nor of contractual obligationscalling for payment of foreign exchange issued, approved and outstanding as ofthe date this Act takes effect (July 16, 1959) and the extension thereof, with thesame terms and conditions as the original contractual obligations.

2. repayment of loans contracted by the government of the Philippines withforeign governments and/or private banks and the importation of machineriesand equipment by provinces, cities or municipalities for the exclusive use in theoperation of public utilities fully-owned and maintained by them.

FACTS:

1. Philamlife, a domestic life insurance corporation, and American InternationalReinsurance Company [Airco], a corporation organized under the laws of theRepublic of Panama, entered into an agreement — reinsurance treaty, statingthat on and after the 1st day of January 1950, the philamlife agrees to reinsurewith AIRCO the entire first excess of such life insurance on the lives of personsas may be written Philamlife under direct application over and above itsmaximum limit of retention for life insurance. It is also stipulated that even thoughPhilamlife "is already on a risk for its maximum retention under policiespreviously issued Philamlife can cede automatically any amount, within the limits

specified, on the same terms on which it would be willing to accept the risk for itsown account, if it did not already have its limit of retention."

2. It is conceded that no question ever arose with respect to the remittancesmade by Philamlife to Airco before July 16, 1959, the date of approval of theMargin Law.



3. The Central Bank of the Philippines collected an amount of money as foreignexchange margin on Philamlife remittances to Airco purportedly totalling$610,998.63 and made subsequent to July 16, 1959. Philamlife subsequentlyfiled with the Central Bank a claim for the refund of the same on the ground thatthe reinsurance premiums so remitted were paid pursuant to the January 1, 1950

reinsurance treaty, and, therefore, were pre-existing obligations expresslyexempt from the margin fee.

4. the Monetary Board — in line with the opinion of its Acting Legal Counselresolved that "reinsurance contracts entered into and approved by the CentralBank before July 17, 1959 are exempt from the payment of the 25% foreignexchange margin, even if remittances thereof are made after July 17, 1959,"because such remittances "are only made in the implementation of a mothercontract, a continuing contract, which is the reinsurance treaty."

5. The Auditor of the Central Bank refused to pass in audit Philamlife's claim for

refund.

6. Philamlife sought reconsideration with the Auditor General but was denied.The Auditor General expressed the view that the existence of the reinsurancetreaty of January 1, 1950 did not place reinsurance premia — on reinsuranceeffected on or after the approval of the Margin Law on July 17, 1959 — out of thereach of said statute.

PETITIONERS CONTENTION: The premia remitted were in pursuance of itsreinsurance treaty with Airco of January 1, 1950, a contract antedating theMargin Law, which took effect only on July 16, 1959.

ISSUE: Whether or not the Auditor General's ruling that "remittance of premia oninsurance policies issued or renewed on or after July 16, 1959, or even if issuedor renewed before the said date, but their reinsurance was effected, onlythereafter, are not exempt from the margin fee, even if the reinsurance treatyunder which they are reinsured was approved by the Central Bank before July16, 1959‖ is correct.

HELD: YES. Section 3 expressly withholds the enforcement of the provisions ofsaid Act on "contractual obligations calling for payment of foreign exchangeissued approved and outstanding as of the date this Act takes effect and theextension thereof, with the same terms and conditions as the original contractualobligations."

True, the reinsurance treaty precedes the Margin Law by over nine years.Nothing in that treaty, however, obligates Philamlife to remit to Airco a fixed,certain, and obligatory sum by way of reinsurance premiums. All that thereinsurance treaty provides on this point is that Philamlife "agrees to reinsure."The treaty speaks of a probability; not a reality. For, without reinsurance, no



premium is due. Of course, the reinsurance treaty lays down the duty to remitpremiums — if any reinsurance is effected upon the covenants in that treatywritten. So it is that the reinsurance treaty per se cannot give rise to a contractualobligation calling for the payment of foreign exchange "issued, approved andoutstanding as of the date this Act [Republic Act 2609] takes effect."

For an exemption to come into play, there must be a reinsurance policy or, as inthe reinsurance treaty provided, a "reinsurance cession" which may be automaticor facultative.

There should not be any misapprehension as to the distinction between areinsurance treaty, on the one hand, and a reinsurance policy or a reinsurancecession, on the other.

A reinsurance policy is thus a contract of indemnity one insurer makes withanother to protect the first insurer from a risk it has already assumed. A

reinsurance treaty is merely an agreement between two insurance companieswhereby one agrees to cede and the other to accept reinsurance businesspursuant to provisions specified in the treaty. The practice of issuing policies byinsurance companies includes, among other things, the issuance of reinsurancepolicies on standard risks and also on substandard risks under specialarrangements. The lumping of the different agreements under a contract hasresulted in the term known to the insurance world as "treaties." Such a treaty is,in fact, an agreement between insurance companies to cover the differentsituations described. Reinsurance treaties and reinsurance policies are notsynonymous. Treaties are contracts for insurance; reinsurance policies orcessions are contracts of insurance.

Philamlife's obligation to remit reinsurance premiums becomes fixed and definiteupon the execution of the reinsurance cession. Because, for every life insurancepolicy ceded to Airco, Philamlife agrees to pay premium. It is only after areinsurance cession is made that payment of reinsurance premium may beexacted, as it is only after Philamlife seeks to remit that reinsurance premium thatthe obligation to pay the margin fee arises. Upon the premise that the margin feeof P268,747.48 was collected on remittances made on reinsurance effected on orafter the Margin Law took effect, refund thereof does not come within thecoverage of the exemption circumscribed in Section 3 of the said law.

ISSUE : Whether or not application of Margin Law would impair the obligation ofcontracts.

HELD: Petitioner's point is that if the Margin Law were, applied, it "would havepaid much more to have the continuing benefit of reinsurance of its risks than ithas been required to do so by the reinsurance treaty in question" and that "thetheoretical equality between the contracting parties would be disturbed and oneof them placed at a distinct disadvantage in relation to the other."



Accordingly, when petitioner entered into the reinsurance treaty of January 1,1950 with Airco, it did so with the understanding that the municipal laws of thePhilippines at the time said treaty was executed, became an unwritten conditionthereof. Such municipal laws constitute part of the obligations of contract. It is inthis context that we say that Republic Act 265, the Central Bank Act, enacted on

June 15, 1948 — previous to the date of the reinsurance treaty — became a partof the obligations of contract created by the latter. And under Republic Act 265,reasonable restrictions may be imposed by the State through the Central Bankon all foreign exchange transactions "in order to protect the international reserveof the Central Bank during an exchange crisis." The Margin Law is nothing morethan a supplement to the Central Bank Act; it is a reasonable restriction ontransactions in foreign exchange. It, too, is an additional arm given, the CentralBank to attain its objectives, to wit: (1) "[t]o maintain monetary stability in thePhilippines;" and (2) "[t]o preserve the international value of the peso and theconvertibility of the peso into other freely convertible currencies." On top of allthese is that that statute was enacted in a background of "dangerously low

international reserves." Its purpose is to reduce as far as is practicable theexcessive demand for foreign exchange.

Petitioner complains that reinsurance contracts abroad would be madeimpractical by the imposition of the 25% margin fee. Reasons there are whichshould deter us from giving in to this view. First, there is no concrete evidencethat such imposition of the 25% margin fee is unreasonable. Second, if reallycontinuance of the existing reinsurance treaty becomes unbearable that contractitself provides that petitioner may potestatively write finis thereto on ninety days'written notice. In truth, petitioner is not forced to continue its reinsurance treatyindefinitely with Airco.

There cannot be an impairment of the obligation of contracts. For, the State may,through its police power, adopt whatever economic policy may reasonably bedeemed to promote public welfare, and to enforce that policy by legislationadapted to its purpose.

FIELDMEN'S INSURANCE CO., INC. vs. ASIAN SURETY & INSURANCE,CO., INC.

FACTS: Asian Surety & Insurance Company, Inc. and the Fieldmen's insuranceCompany, Inc. entered into seven (7) reinsurance agreements or treaties 1 underthe general terms of which the former, as the ceding company undertook to cedeto the latter, as the reinsuring company. Said agreements or treaties were to,take effect from certain specific dates and were to be in force until cancelled byeither party upon previous notice of at least three (3) months by registered mailto the other party, the cancellation to take effect as of the 31st of December ofthe year in which the notice was given.



FIELDMEN'S, by means of registered mail, served notice to ASIAN of theformer's desire to be relieved from all participation in its various treaties with thelatter. This communication, although admittedly received by ASIAN did not elicitany reply from ASIAN.

FIELDMEN'S sent another letter to ASIAN expressing regrets at allegedviolations committed by the latter with respect to the various treaties betweenthem; in the same letter, FIELDMENS reiterated its position that it would consideritself "no longer at risk for any reinsurance and/or cession" given by ASIAN whichmight be in force. Not having received any formal reply from ASIAN,FIELDMEN'S sent anew a letter on February 17, 1962 reminding regarding thecancellation of all the reinsurance treaties and cessions. At the same timeFIELDMEN'S requested ASIAN to submit its final accounting of all cessionsmade to the former for the preceding months when the reinsurance agreementswere in force.

Meanwhile one of the risks reinsured with FIELDMENS issued in favor of theGovernment Service Insurance System, became a liability when the insuredproperty was burned. The next day ASIAN immediately notified FIELDMEN'S ofsaid fire loss.

Plaintiff:

FIELDMEN'S, relying on the sufficiency of its notice of termination and obviouslybent on avoiding its liability under the reinsurance agreements with ASIAN, fileda petition for declaratory relief to seek a declaration that all the reinsurancecontracts entered into between them had terminated

Defendant:

Asian contended that even the 19 letter were considered sufficient notice ofcancellation — thereby rendering the reinsurance agreements terminated as ofDecember 31, 1961 — the liability of FIELDMEN'S with respect to policies orcessions issued under two of the said agreementsprior to their cancellationcontinued to have full force and effect until the stated expiry dates of suchpolicies or cession.

ISSUE: whether or not said cancellation had the effect of terminating also the

liability of FIELDMEN'S as reinsurer.

RULING: No. The two reinsurance agreements with the express stipulationsaforequoted are concerned there is clearly no merit in FIELDMEN'S claim thattheir cancellation carried with it ipso facto the termination of all reinsurancecessions thereunder. Such cessions continued to be in force until their respectivedates of expiration. Since it was under one of said agreements, namely, theFacultative Obligatory Reinsurance Treaty-Fire, that the reinsurance cession



corresponding to the GSIS policy had been made, FIELDMEN'S cannot avoidliability which arose by reason of the burning of the insured property.

where the reinsurance contracts in question contain provision which clearly andexpressly recognize the continuing effectivity of policies ceded under them for

reinsurance notwithstanding the cancellation of the contracts themselves, theircancellation does not carry with it ipso facto the termination of all reinsurancecessions thereunder. Such cessions continued to be in force until their respectivedates of expirations.

Artex Development Co VS Wellington Insurance

FACTS:

Wellington insurance insured for P24,346,509 the building stocks and machineryof plaintiff Artex against loss or damage by fire or lightning up on august 2, 1963

with an additional sum of P833,034.

Another insurance against business interruption (use and occupancy) forP5,200,000.

On September 22, 1963 the building, and machineries were burned and a noticeof loss and damage was given to Wellington.

Insurance adjusters computed the loss for the fire as P10,106,544.40 andWellington paid only 6,481,870.07, leaving a balance of 3,624,683.43

The computed business interruption loss was P3M but Wellington paidonlyP1,864,134.08 leaving a balance of P1,748,460 (computation based oncase)

Artex through counsel Norberto Quisumbing made a manifestation that onlyabout P397,000 is the remaining balance and liability which was the subject ofreinsurance with Alexander and Alexander Inc, of New York, Artexacknowledging here the receipt of P3,600,000 as FINAL and FULLSETTLEMENT of all claims against Wellington

Artex further prays to the court to affirm the lower court‘s decision of liquidation

and prayed for modification of the amount of liability to be fixed to P397,813.00plus 12% interest per annum thereof for the late payment until April 10, 1969 andattorney‘s fees of 15% of the recovery, expenses of litigation, no writ of executionhowever to be made within 3 years from july10, 1969 per collateral agreement ofthe parties.

Wellington in its brief raises the issue that Artex deemed to have agreed to lookSOLELY to the reinsurers for indemnity in case of loss since their paid up capital



stock is only P500,000 and that they have to secure such reinsurance coveragethe over P24M fire insurance coverage of the policy issued by Wellington to

Artex.

Issue:

Does reinsurance contract of the parties make the insured look SOLELY to thereinsurers for indemnity in case of loss?

Ruling:

Nooooooo! The insured who is not directly a party or privy to the reinsurancecontract between Wellington and Alexander and Alexander Inc. cannot demandenforcement of such insurance contracts. The Contracts take effect only betweenthe parties, their assigns and heirs as provide by Art 1311 of our civil code.Further it provides that a contract with stipulations pour autrui or in favor of a third

person not a party to the contract, the parties must have CLEARLY andDELIBERATELY conferred favor upon a third person. Assuming that plaintiff-insured could avail of the reinsurance contracts and directly sue the reinsurersfor payment of the loss, still such assumption would not in any way affect orcancel out defendant-insurer's direct contractual liability to plaintiff-insured underthe insurance policy to indemnify plaintiff for the property losses. Plaintiff's rightas insured to sue defendant as insurer directly and solely would thereby not beaffected or curtailed in any way, without prejudice to defendant in turn filing athird party complaint or separate suit against its reinsurers.

AVON INSURANCE PLC VS CA

By Jo-anne Perez on Tuesday, February 4, 2014 at 12:20amFacts: On July 6, 1979 and on October 1, 1980, Yupangco Cotton Mills engaged

to secure with Worldwide Security and Insurance Co. Inc., several of its

properties for the periods July 6, 1979 to July 6, 1980 for 100,000,000 and from

October 1, 1980 to October 1, 1981 for 100,000,000. Both contracts were

covered by reinsurance treaties between Worldwide Surety and Insurance and

several foreign reinsurance companies, including the petitioners. The

reinsurance arrangements had been made through international broker C.J.

Boatright and Co. Ltd., acting as agent of Worldwide Surety and Insurance.

Within the respective effectivity periods of Policies 20719 and 25896, the

properties therein insured were razed by fire , thereby giving rise to the obligationof the insurer to indemnify the Yupangco Cotton Mills. Partial payments were

made by Worldwide Surety and Insurance and some of the reinsurance

companies.

Within the respective effectivity periods of Policies 20719 and 25896, the

properties therein insured were razed by fire , thereby giving rise to the obligation

of the insurer to indemnify the Yupangco Cotton Mills. Partial payments were

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made by Worldwide Surety and Insurance and some of the reinsurance

companies.

Service of summons upon the petitioners was made by notification to the

Insurance Commissioner, pursuant to Section 14, Rule 14 of the Rules of Court.

In a Petition for Certiorari filed with the Court of Appeals, petitioners submitted

that respondent Court has no jurisdiction over them, being all foreigncorporations not doing business in the Philippines with no office, place of

business or agents in the Philippines.

ISSUE: whether or not the petitioners were determined to be ―doing business in

the Philippines‖ or not.

HELD: ―There is no exact rule of governing principle as to what constitutes doing

or engaging in or transacting business. Indeed, such case must be judged in the

light of its peculiar circumstances, upon its peculiar facts and upon the language

of the statute applicable. The true test, however, seems to be whether the

foreign corporation is continuing the body or substance of the business or

enterprise for which it was organized. Article 44 of the Omnibus Investments Code of 1987 defines the phrase to

include:

'soliciting orders, purchases, service contracts opening offices, whether called

‗liaison offices of branches; appointing representatives or distributors who are

domiciled in the Philippines or who in any calendar year stay in the Philippines

for a period or periods totaling one hundred eighty (180) days or more;

participating in the management, supervision or control of any domestic business

firm, entity or corporation in the Philippines, and any other act or acts that imply a

continuity or commercial dealings or arrangements and contemplate to that

extent the performance of acts or works, or the exercise of some of the functionsnormally incident to and in progressive prosecution of, commercial gain or of

purpose and object of the business organization.‘‖

A single act or transaction made in the Philippines, however, could not qualify a

foreign corporation to be doing business in the Philippines, if such singular act is

not merely incidental or casual, but indicates the foreign corporation‘s intention to

do business in the Philippines.

There is no sufficient basis in the records which would merit the institution of this

collection suit in the Philippines. More specifically, there is nothing to

substantiate the private respondent‘s submission that the petitioners had

engaged in business activities in this country. This is not an instance where theerroneous service of summons upon the defendant can be cured by the issuance

and service of alias summons, as in the absence of showing that petitioners had

been doing business in the country, they cannot be summoned to answer for the

charges leveled against them.

The Court is cognizant of the doctrine is Signetics Corp. vs. Court of Appeals that

for the purpose of acquiring jurisdiction by way of summons on a defendant

foreign corporation, there is no need to prove first the fact that defendant is doing



business in the Philippines. The plaintiff only has to allege in the complaint that

the defendant has an agent in the Philippines for summons to be validly served

thereto, even without prior evidence advancing such factual allegation.

As it is, private respondent has made no allegation or demonstration of the

existence of petitioners‘ domestic agent, but avers simply that they are doing

business not only abroad but in the Philippines as well. It does not appear at allthat the petitioners had performed any act which would give the general public

the impression that it had been engaging, or intends to engage in its ordinary and

usual business undertakings in the country. The reinsurance treaties between

the petitioners and Worldwide Surety and Insurance were made through an

international insurance brokers, and not through any entity of means remotely

connected with the Philippines. Moreover there is authority to the effect that a

reinsurance company is not doing business in a certain state merely because the

property of lives which are insured by the original insurer company are located in

that state. The reason for this is that a contract or reinsurance is generally a

separate and distinct arrangement from the original contract of insurance, whosecontracted risk is insured in the reinsurance agreement. Hence, the original

insured has generally no interest in the contract of reinsurance.

ACCORDINGLY, the decision appealed from dated October 11, 1990, is SET

ASIDE and the instant petition is hereby GRANTED. The respondent Regional

Trial Court of Manila, Branch 51 is declared without jurisdiction to take

cognizance of Civil Case No. 86-37932, and all its orders and issuances in

connection therewith are hereby ANNULLED and SET ASIDE. The respondent

court is hereby ORDERED to DESIST from maintaining further proceeding in the

case aforestated.

6th Batch- Insurance Cases

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