Case Digest (G.R. No. 198172) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Armando Geagonia vs. Court of Appeals and Country Bankers Insurance Corporation (G.R. No. 114427, February 6, 1995), petitioner Armando Geagonia owned Norman’s Mart in the public market of San Francisco, Agusan del Sur. On December 22, 1989, he secured Fire Insurance Policy No. F-14622 from Country Bankers Insurance Corporation for ₱100,000, co-insured with Mercantile Insurance Co., Inc. for ₱50,000. His declared stock-in-trade totaled ₱392,130.50. Policy Condition 3 required the insured to notify the insurer of any other fire policies covering the same property or risk, unless total insurance did not exceed ₱200,000. On May 27, 1990, a fire destroyed Geagonia’s stocks, prompting him to claim under Policy No. F-14622. On December 28, 1990, Country Bankers denied the claim, citing two existing fire policies (Nos. GA-28146 and GA-28144) from Philippines First Insurance Co., Inc. (PFIC), each for ₱100,000, naming “Discount Mart (Mr. Armando Geagonia, Prop.)” as assured with a mo...
Case Digest (G.R. No. 198172) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Insurance policy with Country Bankers Insurance Corporation
- On December 22, 1989, Armando Geagonia (petitioner) obtained Fire Insurance Policy No. F-14622 for ₱100,000.00 covering his stock-in-trade at Norman’s Mart in San Francisco, Agusan del Sur.
- The policy term ran from December 22, 1989 to December 22, 1990; co-insurance declared with Mercantile Insurance Co., Inc. for ₱50,000.00.
- Prior PFIC policies naming Geagonia and mortgage clause
- Philippines First Insurance Co., Inc. (PFIC) issued two policies (GA-28146 and GA-28144), each for ₱100,000.00, naming “Messrs. Discount Mart (Mr. Armando Geagonia, Prop.)” as assured.
- Both contained a simple mortgage (loss-payable) clause in favor of Cebu Tesing Textiles “as their interest may appear.”
- Condition 3 of Country Bankers policy
- Required insured to notify and furnish particulars of any other insurance on the same stock-in-trade, otherwise forfeiture of benefits “provided however, that this condition shall not apply when the total insurance … is not more than ₱200,000.00.”
- Fire loss and claim denial
- On May 27, 1990, a fire destroyed petitioner’s insured stocks.
- Country Bankers denied the ₱100,000.00 claim on December 28, 1990, citing petitioner’s alleged non-disclosure of the PFIC policies in violation of Condition 3.
- Insurance Commission proceedings (I.C. Case No. 3340)
- Petitioner filed for recovery of ₱100,000.00 plus attorneys’ fees; admitted knowledge of PFIC policies but claimed no knowledge of Condition 3’s notice requirement.
- On June 21, 1993, the Commission ruled for petitioner, holding he lacked knowledge of the PFIC policies and that these were procured by Cebu Tesing Textiles; awarded ₱100,000.00 with interest and ₱10,000.00 attorneys’ fees.
- Court of Appeals review (CA-G.R. SP No. 31916)
- Country Bankers appealed; CA found petitioner did know of PFIC policies based on his January 18, 1991 letter (judicial admission) and premium invoices.
- CA reversed the Insurance Commission, ruling that petitioner violated Condition 3 and was precluded from recovery.
- Petition for review to the Supreme Court
- Petitioner challenged CA’s factual findings and reliance on non-evidentiary matters, invoking grave abuse of discretion.
- SC granted review under Rule 45.
Issues:
- Knowledge and non-disclosure
- Whether petitioner knew of the PFIC policies when he obtained Policy No. F-14622.
- Whether failure to disclose these policies violated Condition 3 and forfeited his recovery.
- Validity and scope of Condition 3
- Whether Condition 3’s “other insurance” clause applies to separate insurable interests of mortgagor and mortgagee.
- Whether the proviso limiting forfeiture when total insurance does not exceed ₱200,000.00 applies here.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)