Case Digest (G.R. No. 186983)
Facts:
Ma. Lourdes S. Florendo v. Philam Plans, Inc., Perla Abcede and Ma. Celeste Abcede, G.R. No. 186983, February 22, 2012, the Supreme Court Third Division, Abad, J., writing for the Court. The petition arises from a dispute over benefits under a comprehensive pension plan that included a life insurance component.Petitioner Ma. Lourdes S. Florendo is the widow and beneficiary of Manuel Florendo, who on October 23, 1997 applied for a comprehensive pension plan sold by respondent Philam Plans, Inc. The plan had a pre-need price of P997,050.00 and a maturity value of P2,890,000.00. Manuel signed the application but left Perla Abcede (respondent) to supply the necessary information; Perla’s daughter, Ma. Celeste Abcede, signed as sales counselor. The plan’s life insurance coverage was provided under a Group Master Policy issued by Philippine American Life Insurance Company (Philam Life).
Manuel paid quarterly premiums but died of blood poisoning on September 15, 1998, eleven months after issuance. Lourdes filed a claim for the plan proceeds; Philam Plans referred the claim to Philam Life, which denied liability after findings that Manuel had been on maintenance medication for a heart condition (including use of Coumadin), had an implanted pacemaker, and was diabetic and taking insulin. Philam Plans formally declined the claim and Lourdes sued Philam Plans, Perla and Ma. Celeste before the Regional Trial Court (RTC) of Quezon City.
On March 30, 2006 the RTC ruled for Lourdes and ordered Philam Plans, Perla and Ma. Celeste, jointly and severally, to pay the plan benefits (including the pre-need price and the term insurance proceeds) plus moral damages and costs, finding Manuel did not conceal his health conditions. On December 18, 2007 the Court of Appeals (CA) in CA-G.R. CV 87085 reversed, holding that Manuel (an applicant to an insurance-covered product) bore a duty of disclosure under the doctrine of uberrimae fidei and that his failure to disclose material health conditions entitled the insurer to rescind. The present decision affirms the CA.
Issues:
- Did Manuel conceal his health conditions by leaving medical-history questions blank on his pension plan application, thus permitting rescission?
- Was Manuel bound by the failure of Perla and Ma. Celeste to state his health condition in the application (i.e., is Perla’s action imputed to him)?
- Did Philam Plans’ approval of the application and acceptance of premiums bar it from denying Lourdes’ claim (i.e., was the one-year incontestability clause effective)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)