Facts:

The case involves CCC Insurance Corporation as the petitioner and Carlos F. Robes as the respondent. The events leading to the case began on March 1, 1961, when Carlos F. Robes took out an insurance policy (Policy No. MC-1156) with CCC Insurance Corporation for his Dodge Kingsway car, covering loss or damage due to accidents for an amount not exceeding P8,000. On June 25, 1961, while the policy was still in effect, the insured vehicle was involved in a collision along Rizal Avenue Extension in Potrero, Malabon, Rizal, while being driven by Robes' driver, Domingo Reyes. The car sustained significant damage, with repair costs estimated at P5,300. When Robes sought indemnification from CCC Insurance Corporation, the company refused to pay for the repairs, claiming that the driver was not an "authorized driver" under the terms of the insurance policy. Consequently, Robes filed Civil Case No. Q-6063 in the Court of First Instance of Rizal, seeking not only the repair...

Facts:

1. Insurance Policy: On 1 March 1961, Carlos F. Robes insured his Dodge Kingsway car with CCC Insurance Corporation under Policy No. MC-1156, covering loss or damage through accident for up to P8,000.00.
2. Accident: On 25 June 1961, during the policy's effectivity, the insured vehicle, driven by Robes' driver, Domingo Reyes, was involved in a collision along Rizal Avenue Extension, Potrero, Malabon, Rizal. The car sustained damage, with repair costs estimated at P5,300.00.
3. Claim and Denial: Robes filed a claim with CCC Insurance Corporation, but the insurer refused to pay, alleging that Reyes was not an "authorized driver" under the policy.
4. Lawsuit: Robes filed Civil Case No. Q-6063 in the Court of First Instance of Rizal, seeking recovery of repair costs, actual and moral damages, attorneys' fees, and costs.
5. Trial Court Decision: The trial court ruled in favor of Robes, ordering CCC Insurance to pay P5,031.28 for repairs, P150.00 for hauling and impounding, P2,000.00 as actual damages, and P1,000.00 as attorneys' fees, plus costs.
6. Appeal to Court of Appeals: CCC Insurance appealed, questioning the driver's qualifications and the awards for repairs, actual damages, and attorneys' fees. The Court of Appeals affirmed the trial court's decision but eliminated the P2,000.00 actual damages award as speculative.
7. Petition for Review: CCC Insurance filed a petition for review with the Supreme Court, raising two issues: (a) irregularities in the trial court proceedings, and (b) the driver's lack of authorization under the policy.

Issue:

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Ruling:

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Ratio:

1. Authorized Driver: The insurance policy defined an "authorized driver" as the insured or any person driving with the insured's permission, provided the driver is licensed under applicable laws. Reyes' possession of a driver's license, even if obtained without examination, was sufficient to qualify him as an authorized driver under the policy. The insurer bore the burden of proving the license's invalidity, which it failed to do.
2. Liberal Interpretation of Insurance Policies: Insurance policies are to be interpreted liberally in favor of the insured and strictly against the insurer. The Court found no breach of the policy's terms.
3. Procedural Waiver: Procedural objections must be raised seasonably. CCC Insurance's failure to raise the issue of the clerk of court's role during the trial court proceedings constituted a waiver of the objection. The alleged irregularities were non-prejudicial and did not justify a new trial.