G.R. No. L-25920 - CCC Insurance Corp. vs. Court of Appeals

On March 1, 1961, Carlos F. Robes obtained an insurance policy (Policy No. MC-1156) from CCC Insurance Corporation covering his Dodge Kingsway car against loss or damage through accidents for an amount not exceeding P8,000.00.
The insurance policy included a provision identifying the “AUTHORIZED DRIVER” as:

(a) The insured himself; or
(b) Any person driving on the insured’s order or with his permission, provided that such person is permitted under licensing laws or regulations to operate the motor vehicle or has been so authorized and is not disqualified by court order or any enactment or regulation.

On June 25, 1961, during the policy’s effectivity, the insured vehicle was involved in a collision along Rizal Avenue Extension, Potrero, Malabon, Rizal, while driven by the owner’s driver.
The car sustained damage, with repair estimates amounting to P5,300.00, which included additional costs such as hauling and impounding fees.

Robes initiated Civil Case No. Q-6063 in the Court of First Instance of Rizal (Quezon City) to recover the repair cost (eventually computed at P5,031.28), plus additional claims for actual damages (initially P2,000.00), attorneys’ fees (P1,000.00), and other costs.
The trial court rendered judgment for the plaintiff ordering the insurer to pay for the repairs and other related expenses.

The insurance company (CCC Insurance Corporation) contended that, at the time of the accident, the driver, Domingo Reyes, was not an “authorized driver” as specified in the policy.

a. It was alleged that Reyes did not meet the licensure requirements; he was unable to read and write, and he allegedly secured a driver’s license (License No. 271703 DP) by paying a fee without passing an examination.
b. The Cavite agency of the Motor Vehicles Office certified that it had not issued such license.

The insurer also challenged the conduct of the trial court proceedings on procedural grounds:

a. It alleged irregularities regarding the receipt and submission of evidence by the clerk of court acting as commissioner, including the absence of a written court order, proper oath-taking, request for commission, and formal notice to the parties as required by Rule 33 of the Rules of Court.

The Court of Appeals, in its decision on January 31, 1966, affirmed the trial court’s ruling except for the award of actual damages of P2,000.00, which it struck out as being too speculative.
The appellate court ruled that the contested driver’s license appeared on its face as a duly issued public document; thus, the insurer bore the burden of disproving its genuineness, which it failed to do.
Regarding the procedural challenge concerning the commissioner (the clerk of court), the Court of Appeals held that the procedure followed was within the authority granted under Revised Rule 33 of the Rules of Court and that any alleged irregularity was non-prejudicial and had not been timely objected to at the trial court level.

The insurer argued that Reyes should not be considered an “authorized driver” because of his inability to read or write, his lack of a formal examination, and the irregularities in obtaining his license.
The Court, however, referred to Section 24 of the Revised Motor Vehicles Law (Act 3992, as amended by Republic Acts Nos. 587, 1204, and 2363) and Section 26 of the same Act, which allow that a driver’s license may be issued without an examination at the discretion of the Motor Vehicles Office.
The appellate court noted that Reyes’ long history of driving without mishap since 1957 further supported his qualification as an “authorized driver” under the policy.

Whether the insured car’s damage was covered under the insurance policy given that the driver, Domingo Reyes, was alleged not to be an “authorized driver” due to the irregular manner in which his driver’s license (License No. 271703 DP) was obtained.

Determination of the authenticity and validity of the driver’s license in view of the appellant’s allegations of irregular issuance.
Whether the statutory discretion under Section 24 and Section 26 of the Revised Motor Vehicles Law justifies the issuance of a license without examination.

Whether the conduct of the trial court in receiving and processing the evidence through the clerk of court, acting as commissioner, was valid despite the alleged non-compliance with certain procedural steps under Rule 33 of the Rules of Court.

Consideration of whether the absence of a written commission, oath-taking, or formal notification constituted a procedural defect.
Whether such procedural lapses (if any) had prejudicial effect sufficient to vitiate the trial court’s proceedings and judgment.