Case Digest (G.R. No. 113899)
Facts:
The case is Great Pacific Life Assurance Corp. v. Court of Appeals and Medarda V. Leuterio, G.R. No. 113899, promulgated October 13, 1999, decided by the Supreme Court Second Division, Quisumbing, J., writing for the Court.The petitioner is Great Pacific Life Assurance Corporation (Grepalife); the private respondent is Medarda V. Leuterio, widow of the deceased insured Dr. Wilfredo Leuterio; Development Bank of the Philippines (DBP) appears in the factual background as mortgagee and loss-payable assignee under the group mortgage redemption policy. Grepalife issued a group life/mortgage redemption Certificate No. B-18558 covering Dr. Leuterio after his application on November 11, 1983; the certificate provided coverage up to the outstanding mortgage indebtedness of P86,200.00. The insured answered “No” to prior consultations for heart condition/high blood pressure and “Yes” to being in good health on the application form. Dr. Leuterio died on August 6, 1984, of a massive cerebral hemorrhage; DBP submitted the death claim, which Grepalife denied alleging concealment of hypertension by the insured.
On October 20, 1986, the widow filed Civil Case No. 10788 in the Regional Trial Court (Misamis Oriental, Branch 18) for specific performance with damages against Grepalife to recover the insurance proceeds. The trial court, after hearing evidence including testimony of the attending physician and the death certificate, rendered judgment in favor of the widow on February 22, 1988, ordering payment under the policy (and dismissing certain other claims). Grepalife appealed to the Court of Appeals which affirmed the trial court in a Decision dated May 17, 1993 and in a Resolution dated January 4, 1994 in CA-G.R. CV No. 18341. Grepalife then filed a petition for review under Rule 45 before the Supreme Court challenging (a) that the trial court improperly adjudged liability to DBP although DBP was not a party; (b) that the insurer should have been exonerated for concealment of hypertension by the insured; and (c) that there was no proof of the actual outstanding indebtedness to DBP to justify the P8...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in holding Grepalife liable to DBP (a nonparty) as beneficiary under the group life insurance where the suit was filed by the widow—i.e., was the widow the real party in interest and was DBP an indispensable party?
- Did the Court of Appeals err in finding that Dr. Leuterio committed concealment (non-disclosure of hypertension) that would vitiate the insurance contract?
- Did the Court of Appeals err in affirming liability for P86,200.00 absent proof of the actual outstanding mor...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)