Case Digest (G.R. No. 130421)
Facts:
American Home Assurance Company v. Antonio Chua, G.R. No. 130421, June 28, 1999, Supreme Court First Division, Davide, Jr., C.J., writing for the Court.American Home Assurance Company (petitioner) is a domestic insurer; Antonio Chua (respondent) operated Moonlight Enterprises and sought fire coverage for his stock-in-trade. The original policy was to expire on 25 March 1990. On 5 April 1990 respondent allegedly gave petitioner’s agent, James Uy, PCIBank Check No. 352123 for P2,983.50 as premium for renewal; a Renewal Certificate was delivered and an official receipt was later dated 10 April 1990. Petitioner issued a new policy, Policy No. 206-4234498-7, for the period 25 March 1990–25 March 1991 with coverage up to P200,000.
On 6 April 1990 Moonlight Enterprises was destroyed by fire. Respondent filed claims against petitioner and four co-insurers; petitioner refused payment and respondent sued petitioner in the Regional Trial Court (RTC), Makati, Branch 150 (Civil Case No. 91-1009). The RTC found that respondent had paid by check, that petitioner’s agent acknowledged receipt (renewal certificate), that the allegedly fraudulent documents were limited to discrepancies in BIR receipts (but a BIR certification supported respondent), and that petitioner had prior knowledge of other insurers; the RTC ordered petitioner to pay P200,000 (policy amount) plus legal interest, and awarded P200,000 moral damages, P200,000 loss of profit, P100,000 exemplary damages, P50,000 attorney’s fees, and costs.
The Court of Appeals affirmed the RTC decision in CA-G.R. CV No. 40751. Petitioner filed a petition for review on certiorari under Rule 45, challenging (inter alia) the existence of a binding policy at the time of loss (citing...(Pro-only)
Issues:
- Was there a valid payment of premium such that the renewed fire insurance policy was binding at the time of the 6 April 1990 fire?
- Did respondent violate the policy by submitting fraudulent documents or failing to disclose other existing insurance, thereby voiding coverage?
- Are the damages awarded by the trial court (amount of insurance, moral damages, loss of profit, exemplary damages, attorney’s fees) proper a...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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