Case Digest (G.R. No. 113899) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Great Pacific Life Assurance Corp. v. Court of Appeals and Medarda V. Leuterio, G.R. No. 113899, decided October 13, 1999, the petitioner, Great Pacific Life Assurance Corporation (Grepalife), entered into a group life insurance contract (Policy No. G-1907, Cert. B-18558) with the Development Bank of the Philippines (DBP) to insure eligible housing loan mortgagors. On November 11, 1983, Dr. Wilfredo Leuterio, a DBP borrower, answered in his application form that he was in good health and had never consulted a physician for hypertension or other serious ailments. Four days later, Grepalife issued him coverage equivalent to his outstanding mortgage of ₱86,200.00. On August 6, 1984, Dr. Leuterio died of a massive cerebral hemorrhage, possibly secondary to hypertension. DBP filed a death claim, which Grepalife denied, alleging material concealment of hypertension. On October 20, 1986, Medarda V. Leuterio, the widow-beneficiary, sued for specific performance with damages before th... Case Digest (G.R. No. 113899) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract and Application
- Great Pacific Life Assurance Corp. (Grepalife) entered into Group Policy No. G-1907 with Development Bank of the Philippines (DBP) to insure housing-loan mortgagors.
- On November 11, 1983, Dr. Wilfredo Leuterio applied, answering “No” to prior heart, hypertension or other conditions and “Yes” to being in good health.
- Certificate, Death and Claim
- On November 15, 1983, Grepalife issued Certificate No. B-18558 covering Dr. Leuterio’s mortgage indebtedness of ₱86,200.
- Dr. Leuterio died on August 6, 1984 of a cerebral hemorrhage; DBP filed a death claim, which Grepalife denied, alleging concealment of hypertension.
- Proceedings Below
- On October 20, 1986, Medarda V. Leuterio (widow) sued Grepalife for specific performance with damages in RTC Misamis Oriental, Branch 18.
- The RTC ruled in favor of the widow; the Court of Appeals affirmed on May 17, 1993. Grepalife then filed this Rule 45 petition.
Issues:
- Real Party in Interest
- Can the widow maintain the suit when DBP, as loss payee, was not joined?
- Concealment Defense
- Did Dr. Leuterio willfully conceal a hypertension condition material to risk?
- Quantum of Recovery
- Is the award of ₱86,200 proper absent proof of actual outstanding mortgage at the time of death?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)