G.R. No. 161651 - Lateo y Eleazar vs. People

On February 17, 2011, petitioner Susan Co Dela Fuente invested ₱2,000,000 in the lending business of Reuben Protacio; additional investments of ₱1,000,000 on March 3 and ₱1,000,000 on March 14, 2011.
On March 10, 2011, Reuben applied for a ₱15,000,000 life insurance policy with Fortune Life Insurance Co., Inc., naming Susan as revocable beneficiary; Policy No. 61761 was issued on March 25, 2011 upon payment of ₱82,500.

Reuben died on April 15, 2011 of a gunshot wound to the chest; Susan filed a claim for the policy proceeds.
Fortune’s investigation relied on a Clinical Abstract by Dr. Pagayatan recounting Randolph Protacio’s statement that Reuben “wanted to die,” and on Dr. Fortun’s interpretation of records; it denied the claim as suicide and refunded Susan ₱80,643, which she refused.

RTC Decision (Feb. 27, 2015): Found no proof of suicide; awarded Susan ₱15,000,000 plus 12% interest from May 18, 2011, ₱50,000 attorney’s fees, and costs.
CA Decision (Feb. 17, 2016): Admitted Randolph’s statement as res gestae and Dr. Fortun’s testimony; held Reuben committed suicide; dismissed the complaint.
SC Petition: Susan filed a Rule 45 petition, raising laches, burden of proof, and extent of insurable interest.

Whether Fortune is barred by laches from questioning the one-day late filing of Susan’s motion for reconsideration.
Whether the insurer bears the burden of proving that the insured’s death was due to suicide.
Whether Susan is entitled to the full ₱15,000,000 face value of the policy despite her insurable interest being only ₱4,000,000 at inception and a prior ₱2,000,000 refund.