Case Digest (G.R. No. 205206)
Facts:
In Bank of the Philippine Islands and FGU Insurance Corporation (presently known as BPI/MS Insurance Corporation) vs. Yolanda Laingo, G.R. No. 205206, decided on March 16, 2016 under the 1987 Constitution, respondent Yolanda Laingo was named beneficiary of a Personal Accident Insurance Coverage Certificate No. 043549 issued by FGU Insurance in favor of her son, Rheozel Laingo, who on July 20, 1999 opened a “Platinum 2-in-1 Savings and Insurance” account (Savings Account No. 2233-0251-11, Passbook No. 50298) with petitioner Bank of the Philippine Islands (BPI) at its Claveria, Davao City branch. This deposit account automatically conferred an insurance policy against disability or death, underwritten by FGU Insurance, without further action from the depositor. On September 25, 2000, Rheozel died in a vehicular accident, and his death was publicized in a local newspaper the following day. Two days later, Laingo’s personal secretary inquired at BPI regarding the account, and througCase Digest (G.R. No. 205206)
Facts:
- Account Opening
- On July 20, 1999, Rheozel Laingo opened a “Platinum 2-in-1 Savings and Insurance” account with Bank of the Philippine Islands (BPI), Claveria, Davao City branch.
- The product combined a savings account (Passbook No. 50298; Account No. 2233-0251-11) and an automatic personal accident insurance policy issued by FGU Insurance Corporation (Certificate No. 043549), with respondent Yolanda Laingo as named beneficiary.
- Death of the Insured and Initial Withdrawal
- Rheozel died in a vehicular accident on September 25, 2000 (Certificate of Death, Civil Registrar General of Tagum City).
- On September 27, 2000, Yolanda Laingo’s representative withdrew ₱995,000 from the savings account to cover funeral expenses. BPI personnel facilitated the transaction without informing her of the insurance coverage.
- Discovery of Insurance Policy and Administrative Claim
- On January 21, 2003, Rheozel’s sister found the insurance certificate among his belongings and informed Laingo.
- Laingo wrote to BPI and FGU Insurance on September 11 and November 7, 2003, requesting processing of her insurance claim.
- On February 19, 2004, FGU Insurance denied the claim for late filing, citing the three-month notice requirement under Paragraph 15 of the Policy.
- Judicial Proceedings
- Laingo filed a Complaint for Specific Performance with Damages and Attorney’s Fees on February 20, 2004, in RTC Davao City, Branch 16.
- RTC Decision (April 21, 2008): Dismissed complaint, ruling the 90-day prescriptive period runs from death, not from beneficiary’s knowledge.
- CA Decision (June 29, 2012): Reversed RTC, held that beneficiary not bound by notice period she did not know; awarded actual damages, attorney’s fees, and insurance proceeds with interest.
- CA Resolution (December 11, 2012): Denied petitioners’ motion for reconsideration.
- Petitioners filed for review on certiorari under Rule 45 before the Supreme Court.
Issues:
- Whether a named beneficiary who lacked knowledge of the insurance policy is bound by the three-calendar-month written-notice-of-claim requirement upon the insured’s death.
- Whether BPI, as agent of FGU Insurance, breached its duty by failing to notify the beneficiary of the policy and its conditions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)