Case Digest (G.R. No. 243733)
Facts:
This case involves Edita A. De Leon, Lara Bianca L. Sarte, and Renzo Edgar L. Sarte (petitioners) who filed a Petition for Review on Certiorari under Rule 45, challenging the Court of Appeals’s July 20, 2017 Decision and December 13, 2018 Resolution affirming the Regional Trial Court of Makati City’s December 22, 2015 Decision in Civil Case No. 04-941. The controversy arose from a complaint for interpleader initiated by respondent The Manufacturers Life Insurance Company (Phils.) Inc. (“Manulife”) on August 12, 2004, to determine the rightful beneficiaries of three life insurance policies issued to the late Edgar H. Sarte, who died December 23, 2003. Sarte had three families: with his lawful wife Zenaida S. Sarte (and their children Jessica and Eldon), with Vilma C. Caparros (and their children Alvin and Angelo), and with Edita De Leon (and their children Lara and Renzo). On March 1, 2002, Sarte executed Beneficiary Designation Forms (“BDFs”) registering changes in Manulife’s reCase Digest (G.R. No. 243733)
Facts:
- Parties and Insurance Policies
- Edgar H. Sarte (deceased insured) sired three families:
- With Zenaida S. Sarte (legitimate wife): Jessica S. Sarte-Gustilo and Edgard Eldon S. Sarte.
- With Vilma C. Caparros: Edgar Alvin C. Sarte and Edgar Angelo C. Sarte.
- With Edita A. De Leon: Lara Bianca L. Sarte and Renzo Edgar L. Sarte.
- Three life insurance policies (all revocable beneficiaries) issued by Manufacturers Life Insurance Company (Phils.), Inc. (Manulife):
- Beneficiary Designation Forms (BDFs) and Dispute
- March 1, 2002 BDFs (processed and registered by Manulife):
- Policy 1: Zenaida Sarte & Jessica Sarte-Gustilo
- Policy 2: Zenaida Sarte & Renzo Edgar L. Sarte
- Policy 3: Edgar Alvin C. Sarte & Renzo Edgar L. Sarte
- July 31, 2002 BDFs (prepared by Sarte’s secretary Gealogo, signed by Sarte; originals delivered to servicing agent Betty Cepeda):
- Policy 1 changed to: Renzo Edgar L. Sarte
- Policy 2 changed to: Renzo Edgar L. Sarte
- Policy 3 changed to: Lara Bianca L. Sarte
- Death of Edgar Sarte on December 23, 2003. Manulife did not pay proceeds pending resolution of conflicting claims.
- August 12, 2004: Manulife filed complaint for interpleader before RTC Makati to determine rightful beneficiaries among:
- Zenaida & Jessica;
- Vilma & minor Alvin;
- Edita & minors Lara and Renzo.
- Counterclaims and third-party complaints:
- Zenaida/Jessica and Alvin alleged bad faith and sought damages against Manulife.
- Lara/Renzo filed counterclaim against Manulife and third-party complaint against Cepeda for failing to register BDFs.
- Cepeda counter-claimed against Lara/Renzo for damages defending frivolous suit.
Issues:
- Did the insurance policies or governing law require Sarte to designate a trustee when naming minor beneficiaries?
- Did the Court of Appeals correctly apply the Best Evidence Rule in excluding photocopies of the July 31, 2002 BDFs?
- Did Sarte effect a valid change of beneficiary by submitting the July 31, 2002 BDFs as a “written notice in form satisfactory to the Company”?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)