Case Digest (G.R. No. 214781)
Facts:
In the case where Country Bankers Insurance Corporation is the petitioner and Lianga Bay and Community Multi-Purpose Cooperative, Inc. (the respondent) is involved, the dispute centers around an insurance claim related to a fire incident that occurred on July 1, 1989. The petitioner, primarily engaged in the insurance business, had issued Fire Insurance Policy No. F-1397 to the respondent, insuring its stocks-in-trade against fire-related loss for a period extending from June 20, 1989, to June 20, 1990, with coverage up to Two Hundred Thousand Pesos (₱200,000.00). The respondent's building located in Barangay Diatagon, Lianga, Surigao del Sur, was completely destroyed in a fire around 12:40 AM on the specified date, which resulted in total loss of its inventory and assets. Following the event, the respondent filed an insurance claim supported by documents including a Spot Report from Pfc. Arturo V. Juarbal and sworn statements from witnesses Jose Lomocso and Ernesto Urbizto
Case Digest (G.R. No. 214781)
Facts:
- Insurance Contract and Coverage
- The petitioner, Country Bankers Insurance Corporation, entered into a fire insurance contract with the respondent, Lianga Bay and Community Multi-Purpose Cooperative, Inc. under Fire Insurance Policy No. F-1397.
- The policy insured the respondent’s stocks-in-trade against fire loss during the period from June 20, 1989 at 4:00 p.m. to June 20, 1990 at 4:00 p.m. for the sum of P200,000.00.
- Fire Incident and Claim Filing
- On July 1, 1989, at about 12:40 a.m., the respondent’s building in Barangay Diatagon, Lianga, Surigao del Sur was completely gutted by fire, resulting in a total loss of stocks-in-trade, furniture, fixtures, equipment, and records.
- In response to the loss, the respondent filed an insurance claim under the policy and submitted the following supporting documents:
- The Spot Report of Pfc. Arturo V. Juarbal, the investigating officer.
- The Sworn Statement of Jose Lomocso.
- The Sworn Statement of Ernesto Urbiztondo.
- Denial of the Insurance Claim
- The petitioner denied the claim, arguing that the fire was caused by two NPA rebels who set the building on fire to obtain canned goods, rice, and medicines.
- The petitioner maintained that such loss was an excepted risk under paragraph 6 of the policy conditions, which excludes coverage for losses resulting from occurrences such as mutiny, riot, insurrection, or rebellion.
- Litigation and Court Decisions
- Finding the denial unacceptable, the respondent instituted a complaint for recovery of the loss against the petitioner in the Regional Trial Court of Lianga, Surigao del Sur.
- The trial court, in its Decision dated December 26, 1991, ruled in favor of the respondent, ordering the petitioner to:
- Pay the full insurance claim of P200,000.00 with interest at 12% per annum from the filing of the complaint until payment in full.
- Pay additional amounts as actual damages (P50,000.00), exemplary damages (P50,000.00), litigation expenses (P5,000.00), attorney’s fees (P10,000.00), and the costs of the suit.
- The Court of Appeals affirmed the trial court’s decision in its entirety on December 29, 1998.
- Petition for Review on Certiorari and Petitioner’s Arguments
- The petitioner filed a petition for review on certiorari, raising three primary assigned errors:
- Failure by the Court of Appeals to give credence to the Spot Report and Sworn Statement which purportedly showed that loss was due to NPA rebel action, an event constituting an excepted risk.
- Erroneous imposition of interest at 12% per annum from the filing of the complaint.
- Incorrect award of actual damages, exemplary damages, litigation expenses, and attorney’s fees.
- The petitioner contended that the evidence it presented should have supported its defense that the loss arose from an excepted risk, thereby relieving it of liability under the policy.
Issues:
- Whether the Court of Appeals erred in accepting the evidence (the Spot Report and Sworn Statements) that alleged the cause of the fire was the act of NPA rebels, thereby characterizing the loss as an excepted risk under the fire insurance policy.
- Whether it was erroneous to impose an interest rate of 12% per annum from the filing of the complaint on the face value of the policy, given the applicable legal guidelines for interest rates in such cases.
- Whether the trial court was justified in awarding actual damages, exemplary damages, litigation expenses, and attorney’s fees against the petitioner without sufficient evidentiary basis and legal justification.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)