Facts:

On April 20, 1952, Rufino D. Andres filed a complaint against the Crown Life Insurance Company in the Court of First Instance of Ilocos Norte, seeking to recover P5,000, the face value of a joint 20-year endowment insurance policy issued in favor of him and his wife, Severa G. Andres, on February 13, 1950. Severa passed away on May 3, 1951, and Rufino submitted a death claim as the survivor-beneficiary on June 7, 1951. The insurance company denied the claim on April 20, 1952, leading to the initiation of this case. The defendant, Crown Life Insurance Company, responded by disclaiming liability and asserting that the policy had lapsed due to non-payment of premiums.

The parties later submitted a stipulation of facts on March 25, 1954, detailing the timeline of events surrounding the insurance policy. The policy was issued on February 13, 1950, with premiums due semi-annually. The first premium was paid on November 25, 1949, and the second on June 24, 1950. However, the thir...

Facts:

Background of the Case

• On April 20, 1952, Rufino D. Andres filed a complaint in the Court of First Instance of Ilocos Norte against the Crown Life Insurance Company seeking the recovery of P5,000, which was the face value of a joint endowment policy.
• The insurance policy, issued on February 13, 1950 (Policy No. 536,423), was taken out in favor of Rufino D. Andres and his wife, Severa G. Andres, covering a 20-year term with a face value of P5,000.

Payment of Premiums and Lapse of the Policy

• The policy required semi-annual premium payments of P165.15. The first payment for the period from November 25, 1949, to May 25, 1950, was made on November 25, 1949, and the second was paid on June 24, 1950.
• The premium for the third semester (November 25, 1950, to May 25, 1951) was not paid, leading to the lapse of the policy on December 25, 1950, following the expiration of the customary 31-day period of grace.

Communications Concerning Reinstatement

• On January 6, 1951, the insurance company, through its representative Mr. I. B. Melendres, informed the Andres couple that the policy had lapsed and that an overdue premium of P165.15 was due, offering a period of 60 days for filing an application for reinstatement.
• Subsequent communications from February 12, 1951, reiterated the lapse of the policy, and both Rufino and Severa Andres executed applications for reinstatement on the same month.
• On February 20, 1951, the plaintiff sent a letter with a money order for P100, addressing part of the overdue premium, while the balance of P65.15 was later remitted on May 5, 1951 (received May 11, 1951).

Subsequent Developments and Death Claim

• On June 7, 1951, Rufino Andres presented his death claim as the survivor-beneficiary following the death of his wife, Severa G. Andres, who passed away on May 3, 1951.
• The claim included supporting documents: an affidavit (dated June 6, 1951), a Certificate of Death (May 29, 1951), and a medical certificate detailing the cause of death.
• On June 30, 1951, the insurance company communicated its reasons for refusing the claim, and further correspondences continued to address the balance and reinstatement conditions.

Stipulation of Facts and Lower Court Decision

• On March 25, 1954, the parties provided a stipulation of facts along with numerous exhibits detailing the communications, payments, and letters exchanged regarding the policy and its reinstatement procedure.
• On August 5, 1954, Judge Julio Villamor rendered a decision absolving the insurance company from liability on the ground that the policy, having lapsed due to non-payment, was not reinstated at the time of the insured’s death.
• The plaintiff-appellant later appealed the decision, but the appeal was certified to the Supreme Court because no substantial factual dispute existed.

Issue:

Validity of Reinstatement

• Whether policy No. 536,423, which had lapsed before May 3, 1951, was validly and completely reinstated after its lapse.
• Whether the reinstatement conditions, as stipulated in the policy contract, had been fully complied with by the plaintiff-appellant.

Waiver of the Full Payment Requirement

• Whether the insurer’s communications (Exhibits 4 and 5) amounted to a waiver of the condition requiring full payment of the overdue premium.
• Whether the insurer’s subsequent letters (Exhibits 9 and 10) indicated an acceptance of partial payments in lieu of the stipulated full payment necessary for reinstatement.

Impact on the Death Claim

• Whether the failure to meet the reinstatement requirements before the death of Severa G. Andres deprived the plaintiff of the right to claim the face value of the policy.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)