Case Digest (G.R. No. 210302)
Facts:
Integrated Micro Electronics, Inc. v. Standard Insurance Co., Inc., G.R. No. 210302, August 27, 2020, First Division, Lopez, J., writing for the Court.In March 2009 a panel of insurers, including Standard Insurance Co., Inc., issued Policy No. HOF09FD-FAR086036 in favor of Integrated Micro Electronics, Inc., covering all risks of physical loss (including fire) for March 31, 2009 to March 31, 2010. On May 24, 2009 a fire damaged Integrated Micro’s production equipment and machineries. Integrated Micro filed a claim on May 25, 2009; Standard Insurance denied the claim by letter dated February 24, 2010. Integrated Micro sought reconsideration, which Standard Insurance denied in a letter dated April 12, 2010 that Integrated Micro received on April 15, 2010.
Integrated Micro filed a complaint for specific performance and damages against Standard Insurance in the Regional Trial Court (RTC) on April 11, 2011, claiming US$1,117,056.84 (peso equivalent). Standard Insurance moved to dismiss on grounds of invalid service of summons, lack of cause of action, and prescription; it alleged that summons was served on the legal assistant/secretary of its in‑house counsel (not an authorized recipient under Rule 14, Sec. 11) and that the suit was filed more than twelve months after receipt of the denial. On November 9, 2011 the RTC denied the motion to dismiss and ordered Standard Insurance to file an answer; its motion for reconsideration was denied.
Standard Insurance filed a petition for certiorari with the Court of Appeals (CA) — CA‑G.R. SP No. 124433 — which on March 26, 2013 granted the petition, holding that Integrated Micro’s complaint was time‑barred under the policy’s 12‑month clause (the prescriptive period runs from receipt of the insurer’s rejection) and that service on the in‑house counsel’s legal assistant was invalid; the RTC orders were nullified and set aside. Integrated Micro’s motion for reconsideration in the CA was denied...(Subscriber-Only)
Issues:
- Was service of summons on the legal assistant of respondent’s in‑house counsel valid under Rule 14, Section 11 of the 1997 Rules of Civil Procedure?
- Did Integrated Micro’s cause of action prescribe under the policy’s twelve‑month clause, and if so, from what date does the pres...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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