Case Digest (G.R. No. 203756) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Alpha Plus International Enterprises Corp. vs. Philippine Charter Insurance Corp., petitioner Alpha Plus, an optical media business, secured two fire insurance policies from respondent PCIC covering June 9, 2007 to June 9, 2008. On February 24, 2008, a fire gutted petitioner’s warehouse, destroying machinery and equipment. PCIC denied the claim by letter dated January 22, 2009, received by Alpha Plus on January 24, 2009. After unsuccessful negotiations, Alpha Plus filed a Complaint on January 20, 2010 in RTC, Branch 84, Malolos, Bulacan, for Specific Performance, Collection of Sum of Money and Damages, praying for indemnity per policy, exemplary damages, attorney’s fees, costs, and legal interest. It paid initial docket fees of ₱42,545.00. On February 9, 2010, it filed an Amended Complaint specifying ₱300 million actual damages and “two times the legal interest per annum,” paying additional docket fees of ₱6,056,465.00. Respondents moved to dismiss for lack of cause of action Case Digest (G.R. No. 203756) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Insurance Contract
- Petitioner: Alpha Plus International Enterprises Corp., an optical media business, obtained two fire insurance policies from Philippine Charter Insurance Corp. (PCIC) covering June 9, 2007 to June 9, 2008.
- Respondents: PCIC and its officers (Bienvenido E. Laguesma, Vytonne So, Gerry Y. Tee, Henry M. Sun, Emmanuel R. Que, Benjamin S. Ty, Robert T. Yu, Edwin V. Salvan, Atty. Maria Luisa Cecilia E. Garcia).
- Loss, Claim, and Procedural History
- On February 24, 2008, Petitioner’s warehouse was gutted by fire, destroying stored equipment and machinery.
- PCIC denied the insurance claim via letter dated January 22, 2009 (received January 24, 2009); settlement attempts failed.
- January 20, 2010: Petitioner filed a Complaint (Civil Case No. 41-M-2010) for specific performance, collection of sum of money, and damages; initial docket fees of ₱42,545.00 were paid.
- February 9, 2010: Petitioner filed an Amended Complaint claiming ₱300 million actual damages and double legal interest; additional docket fees of ₱6,056,465.00 were paid.
- Respondents moved to dismiss for lack of cause of action, insufficient fees, and prescription; the RTC denied these motions in orders dated April 5 and June 21, 2011. The CA granted respondents’ petition for certiorari, nullified the RTC orders, and ordered dismissal.
Issues:
- Whether the Court of Appeals erred in ruling that Petitioner’s complaint was already barred by prescription at the time of filing.
- Whether the prescriptive period should run from the filing of the original complaint or from the amended complaint.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)