Case Digest (G.R. No. 109937)
Facts:
Development Bank of the Philippines v. Court of Appeals and the Estate of the Late Juan B. Dans, G.R. No. 109937, March 21, 1994, Supreme Court First Division, Quiason, J., writing for the Court.In May 1987 Juan B. Dans, with his wife Candida G. Dans and other family members, applied for a P500,000 loan from the Development Bank of the Philippines (DBP), Basilan Branch; DBP advised him to obtain Mortgage Redemption Insurance (MRI) from the DBP Mortgage Redemption Insurance Pool (DBP MRI Pool). DBP approved a reduced loan of P300,000 on August 4, 1987 and released it on August 11, 1987; DBP deducted P1,476 as the MRI premium from the loan proceeds. On August 15, 1987 Dans signed an "MRI Application for Insurance" and a "Health Statement for DBP MRI Pool." On August 20, DBP credited the MRI premium (less a 10% DBP service fee) to the MRI Pool's savings account and advised the Pool of the credit.
Dans died of cardiac arrest on September 3, 1987. DBP notified the MRI Pool, which on September 23, 1987 advised DBP that Dans was ineligible for coverage because he exceeded the Pool’s maximum acceptance age of 60. On October 21, 1987 DBP informed Candida Dans of the disapproval and offered to refund the P1,476; she refused, demanding payment equivalent to the loan or the face value of the MRI, and rejected an ex gratia offer of P30,000.
On February 10, 1989 the Estate of Juan B. Dans, through Candida as administratrix, filed suit in the Regional Trial Court, Branch I, Basilan, against DBP and the DBP MRI Pool for "Collection of Sum of Money with Damages," alleging that DBP required Dans to apply for MRI and collected the premium despite knowing his age ineligibility; the complaint prayed for (1) reimbursement of P139,500 paid under protest as loan amortization, (2) declaration that the mortgage debt was fully paid, and (3) damages. DBP and the MRI Pool answered; DBP filed a cross-claim against the Pool. At pre-trial the parties admitted the documentary evidence and the trial court treated the case as ripe for summary judgment.
On March 10, 1990 the trial court rendered judgment for the Estate against DBP and absolved the DBP MRI Pool for lack of privity, finding DBP estopped for having led Dans to apply and for collecting the premium despite knowing of the age limitation. The trial court ordered reimbursement and declared the mortgage satisfied. ...(Pro-only)
Issues:
- Was the DBP Mortgage Redemption Insurance Pool liable to the Estate under an insurance contract?
- Was DBP liable to the Estate for reimbursement of loan payments and other relief for having led Dans to apply for MRI despite his ineligibility?
- Were the awards of moral damages and attorney’s fees proper...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)