G.R. No. 224302 - Aguinaldo vs. Aquino III

Plaintiff: Emilio Gonzalez La O, who insured his leaf tobacco stored in a warehouse.
Defendant: The Yek Tong Lin Fire & Marine Insurance Co., Ltd., the insurer providing coverage on the plaintiff’s tobacco.
The insurance policies at issue stipulated warranties, notably warranties A and G, which required that the building used for insurance purposes not be leased or used for depositing other goods without the company's consent.

On January 11, 1928, a fire destroyed the building at No. 188 Soler Street, Manila, where the plaintiff's leaf tobacco was stored.
The fire caused extensive damage to the stored tobacco, which led the plaintiff to claim a sum of P100,000 from the defendant under one of the insurance policies.
The plaintiff also pursued claims against other assurance companies for additional amounts, which resulted in a compromise settlement in those related cases.

The trial record shows that the plaintiff presented extensive documentary and testimonial evidence:

Official Register Book (Exhibit I) and Official Guide (Exhibit J) from the Bureau of Internal Revenue demonstrating records of the tobacco inventory.
The Stock Book (Exhibit K) kept by the plaintiff, supported by the testimonies of witnesses Claveria, Bonete, and Leoncio Jose.
Testimony and report from Estanislao Lopez, Inspector of Internal Revenue (Exhibit N).
Tobacco invoices (Exhibits L and L-l to L-20) detailing the stock damaged by fire.
Testimony of Clemente Uson, the plaintiff’s auditor and public accountant, corroborating the recorded inventory.

Additional evidence included photographic evidence examined by the defendant’s adjuster, whose later reports (Exhibits TJU, WW, and XX) confirmed that the quantity and value of tobacco in the warehouse exceeded the insured amounts.
The removal of 258 bales, as noted in the Official Register Book, was explained by the urgent circumstances surrounding the fire, and no significant irregularity was found upon further scrutiny.

Multiple exhibits and testimony established that, at the time of the fire, there were over 6,200 bales of leaf tobacco in the warehouse, with a total value exceeding P300,000.
The plaintiff demonstrated the value using both the cost price, as testified by auditor Uson (at approximately P51.8544 per bale), and comparative market price evidence supplied by adjusters (reporting a valuation of not less than P290,000).

The defendant argued that since the building had been leased to other persons after a portion had been ceded to the plaintiff, the implied warranties (A and G) could be invoked to deny full recovery under the policy.
The existence of other insurance policies obtained by the plaintiff was admitted and evidenced by the defendant’s answer, which contested notification requirements and alleged a breach of Article 3 of the policy conditions.
The defendant later claimed that the plaintiff had not properly notified them in writing of other insurances, thereby attempting to invalidate the policies.

Whether the tobacco damaged by the fire was worth at least the amount for which it was insured, i.e., whether its value exceeded or matched P100,000.
Whether the evidence presented sufficiently demonstrated that the quantity and value of the tobacco exceeded the insured amounts.

Whether the defendant could invoke warranties A and G to deny the claim, given that the plaintiff contends the defendant itself was responsible for leasing the warehouse thereafter.
Whether the plaintiff’s failure to notify the defendant in writing of additional insurance policies constituted a breach of Article 3 and rendered the policies null and void.

Whether the cost price, as established by documentary evidence and testimony, was a competent measure for valuing the tobacco destroyed by fire.
Whether the inclusion of the settlement reached in related cases, where the plaintiff accepted eighty-five percent of the claim against other insurers, is proper and relevant in determining the insured value in the instant case.

Whether the defendant’s failure to formally rescind the policy, despite the knowledge of other insurances and alleged breaches, constituted a waiver of its right to void the coverage.
Whether the appellant (defendant) could raise certain errors for the first time on appeal, particularly regarding the conditions of the contract and the notification of other insurances.