Title
Biagtan vs. Insular Life Assurance Co., Ltd.
Case
G.R. No. L-25579
Decision Date
Mar 29, 1972
The case involves a dispute between an insurance company and the beneficiaries of an insured individual who was killed during a robbery, with the court ultimately ruling that the injuries were intentionally inflicted by the robbers, relieving the insurance company from liability for the additional accidental death benefit.
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Case Digest (G.R. No. L-25579)

Facts:

  • The case involves a dispute between the beneficiaries of Juan S. Biagtan and Insular Life Assurance Co., Ltd.
  • Juan S. Biagtan was insured under Policy No. 398075 for P5,000.00, with an additional P5,000.00 under an "Accidental Death Benefit Clause" if his death resulted from bodily injury sustained in an accident.
  • The policy excluded coverage for injuries "intentionally inflicted by a third party."
  • On the night of May 20, 1964, or early hours of May 21, 1964, robbers entered Biagtan's house in Pangasinan.
  • The robbers inflicted nine wounds on Biagtan, five of which were mortal, leading to his death.
  • The robbers were later convicted of robbery with homicide.
  • The insurance company paid the basic amount of P5,000.00 but refused to pay the additional P5,000.00 under the accidental death benefit clause.
  • The insurance company argued that the death resulted from injuries intentionally inflicted by third parties.
  • The beneficiaries filed a suit to recover the additional amount.
  • The Court of First Instance of Pangasinan ruled in favor of the beneficiaries.
  • The insurance company appealed the decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed the decision of the Court of First Instance of Pangasinan.
  • The complaint was dismiss...(Unlock)

Ratio:

  • The Supreme Court held that the injuries inflicted on Juan S. Biagtan by the robbers were intentional.
  • The court emphasized that the accidental death benefit clause excluded coverage for injuries intentionally inflicted by a third party, regardless of the third party's motive.
  • The court distinguished this case from the Calanoc case, where the fatal shot might have been fired to scar...continue reading

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