Case Digest (G.R. No. 10436)
Case Digest (G.R. No. 10436)
Facts:
Francisca Eguaras v. The Great Eastern Life Assurance Company, Ltd., G.R. No. 10436, January 24, 1916, the Supreme Court (Torres, J., writing for the Court; Arellano, C.J., Johnson, Carson, Moreland, and Trent, JJ., concurring).Plaintiff-appellee Francisca Eguaras sued defendants The Great Eastern Life Assurance Company, Ltd. (appellant) and its general agent West G. Smith in the Court of First Instance of Laguna, seeking P5,000 (the face amount of policy No. 5592) plus P1,000 in damages and costs. The complaint alleged that Dominador Albay had applied for life insurance (naming Eguaras beneficiary), that after examination the company issued policy No. 5592 on November 6, 1912, and that Albay died December 6, 1912, but the company refused to pay despite submission of proofs of death.
The defendants demurred (overruled) and pleaded that the policy had been obtained by fraud and deceit and was therefore void. The plaintiff replied that a criminal information for frustrated estafa had been filed against her and others arising from the same transaction but that they had been acquitted (Exhibit B), and pressed her civil claim. After trial the Laguna court on September 14, 1914, ordered the insurance company to pay P5,000 with interest and costs; it absolved W. G. Smith and dismissed the damages claim for lack of proof. The insurer moved for a new trial (denied) and saved bills of exceptions; it appealed to the Supreme Court by bill of exceptions.
At trial the company relied on evidence that the application and supplementary application bore signatures that differed from Albay’s known handwriting, that a substitute person (identified by Dr. Jose A. Vidal and other witnesses as Castor Garcia) had been presented for the medical examination, and that the agent Ponciano Remigio participated in the substitution and had made inculpatory statements. The plaintiff produced an acquittal in the related criminal case and argued the company must pay. The trial court found for plaintiff; the Supreme Court took up issues of contract nullity from deceit and the effect, if any, of the criminal acquittal on the civil suit.
Issues:
- Does the acquittal of the beneficiary and co-accused in the related criminal prosecution (for frustrated estafa) operate as res judicata or estoppel so as to bar the insurance company from asserting in this civil suit that the policy was void for deceit?
- Was policy No. 5592 void for deceit such that the insurer is not obliged to pay the P5,000 face amount to the beneficiary?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)