Case Digest (G.R. No. 198174) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Alpha Insurance and Surety Co. v. Arsenia Sonia Castor, petitioner Alpha Insurance and Surety Co. and respondent Arsenia Sonia Castor entered into Motor Car Policy No. MAND/CV-00186 on February 21, 2007, covering her Toyota Revo DLX DSL for the period February 26, 2007 to February 26, 2008, with a sum insured of ₱630,000.00. On April 16, 2007, at about 9:00 a.m., respondent’s driver, Jose Joel Salazar Lanuza, took the vehicle for a tune-up at a nearby auto shop but never returned it. Respondent reported the theft to the police and notified petitioner, demanding payment under the policy. By letter dated July 5, 2007, petitioner denied the claim, invoking Exception to Section III(4)—“Any malicious damage caused by … a person in the Insured’s service”—to exclude liability. Respondent reiterated her demand in letters of July 12 and August 3, 2007, but was again rebuffed. She then filed a Complaint for Sum of Money with Damages on September 10, 2007 before the Regional Trial Court Case Digest (G.R. No. 198174) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Insurance Policy and Coverage
- On February 21, 2007, respondent Arsenia Sonia Castor entered into Motor Car Policy No. MAND/CV-00186 with petitioner Alpha Insurance and Surety Co., covering her Toyota Revo DLX DSL for the period February 26, 2007 to February 26, 2008.
- The policy provided indemnity of up to ₱630,000.00 for “loss of or damage to” the insured vehicle.
- Theft of the Insured Vehicle
- On April 16, 2007, respondent instructed her driver, Jose Joel Salazar Lanuza, to take the vehicle for a tune-up; the driver never returned it.
- Respondent reported the theft to the police, notified petitioner, and demanded payment of the full insurance proceeds (₱630,000.00).
- Denial of Claim and Commencement of Litigation
- By letter dated July 5, 2007, petitioner denied the claim, invoking “Exceptions to Section III” of the policy, specifically:
- “Any malicious damage caused by the Insured, any member of his family or by a person in the Insured’s service.”
- Respondent maintained that the exception applied only to “damage,” not to “loss,” but petitioner stood by its denial.
- On September 10, 2007, respondent filed a Complaint for Sum of Money with Damages before the RTC of Quezon City.
- Trial Court and Appellate Rulings
- On December 19, 2008, the RTC rendered judgment in favor of respondent ordering petitioner to pay ₱466,000.00 plus 6% interest, attorney’s fees of ₱65,000.00, and costs.
- Petitioner appealed to the Court of Appeals, which on May 31, 2011, affirmed the RTC decision in toto.
- Petitioner’s motion for reconsideration was denied on August 10, 2011.
- Petitioner then filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.
Issues:
- Whether theft of the insured vehicle by the insured’s driver constitutes a “loss” excluded under the policy’s exception for “malicious damage.”
- Whether the terms “loss” and “damage” in the insurance policy are ambiguous and must be construed in favor of the insured.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)