Case Digest (G.R. No. L-19638) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Filipinas Compania de Seguros, Et Al. vs. Hon. Francisco Y. Mandanas (123 Phil. 1246, G.R. No. L-19638, June 20, 1966), thirty-nine non-life insurance companies, all members of the Philippine Rating Bureau, filed a special civil action for declaratory relief in the Court of First Instance of Manila. They sought a declaration that Article 22 of the Bureau’s Constitution—which prohibited members from effecting or accepting reinsurance with any insurer not in good standing with the Bureau—was valid. The Insurance Commissioner, Hon. Francisco Y. Mandanas, challenged Article 22 as constituting an illegal or undue restraint of trade and demanded its repeal by letters dated March 11 and April 11, 1960. On May 9, 1961, he threatened to suspend the Bureau’s license and those of any non-compliant members. In response, on May 16, 1961, the subject petition was filed. Twenty additional companies later intervened in support. The trial court declared Article 22 neither contrary to law nor Case Digest (G.R. No. L-19638) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- Petitioners: Thirty-nine (39) non-life insurance companies, members of the Philippine Rating Bureau, seeking a declaratory judgment on the validity of Article 22 of the Bureau’s Constitution.
- Respondent/Appellant: Hon. Francisco Y. Mandanas, Insurance Commissioner, assailing Article 22 as an illegal or undue restraint of trade.
- Intervenors: Twenty (20) additional non-life insurance companies, members of the Bureau, admitted in support of petitioners.
- Trial Court: The Court of First Instance of Manila rendered judgment declaring Article 22 neither contrary to law nor against public policy, allowing Bureau members to observe and enforce it with no special pronouncement as to costs.
- Correspondence and Pre-Petition Events
- March 11, 1960: Insurance Commissioner’s letter to the Bureau expressing doubts on Article 22 and requesting its repeal.
- April 11, 1960: Follow-up letter inquiring about action taken on the March communication.
- May 9, 1961: Commissioner threatened to suspend the Bureau’s license and member certificates of authority if Article 22 were enforced.
- May 16, 1961: Filing of the special civil action for declaratory relief in the CFI, Manila.
Issues:
- Does Article 22—which provides that Bureau members “agree not to represent nor to effect reinsurance with, nor to accept reinsurance from, any company…not a member in good standing of this Bureau”—constitute an illegal or undue restraint of trade under Philippine law and public policy?
- Does Article 22 conflict with the Insurance Commissioner’s regulatory authority or with statutory rate-filing and approval requirements for non-life insurance premiums?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)