Title
Lalican vs. Insular Life Assurance Co. Ltd.
Case
G.R. No. 183526
Decision Date
Aug 25, 2009
Violeta Lalican sought death benefits from a lapsed insurance policy after her husband's death. The Supreme Court ruled the policy was not reinstated before his death, denying her claim but allowing a refund of payments.

Case Digest (G.R. No. 217120)
Expanded Legal Reasoning Model

Facts:

  • Insurance Contract and Premium Payments
    • In April 1997, Insular Life issued Policy No. 9011992 to Eulogio C. Lalican, with a 20-year endowment flexi plan worth ₱500,000 and two riders of ₱500,000 each, naming his wife Violeta as primary beneficiary.
    • Quarterly premiums of ₱8,062 were due on 24 April, 24 July, 24 October, and 24 January, with a 31-day grace period; nonpayment by end of grace caused automatic lapse.
  • Policy Lapse and Reinstatement Attempts
    • Eulogio paid the July and October 1997 premiums but defaulted on the 24 January 1998 premium; the policy lapsed on 24 February 1998.
    • On 26 May 1998, he filed an Application for Reinstatement with payment of ₱8,062, but was notified he still owed ₱322.48 interest. He was advised to pay subsequent premiums plus interest.
    • On 17 September 1998, he submitted a second reinstatement application through agent Malaluan with deposit of ₱17,500 covering overdue premiums and interest; he died later that day. Insular Life learned of his death on 21 September 1998 and did not process the application.
  • Claim and Trial Proceedings
    • On 28 September 1998, Violeta filed a death-benefit claim; Insular Life denied it on the ground that the policy had lapsed and was never reinstated, offering refund of ₱25,417.
    • Violeta sought reconsideration and later filed suit in October 1999 (RTC Civil Case No. 2177), claiming unfair settlement practice and seeking full policy proceeds of ₱1,500,000 plus interest and fees.
    • RTC dismissed her complaint in August 2007 for failure to prove reinstatement; subsequent motions for reconsideration and appeals were denied as filed out of time.

Issues:

  • Procedural Appealability
    • Whether the August 30, 2007 RTC decision may still be reviewed despite its finality and the petitioner’s erroneous mode of appeal.
    • Whether equitable considerations or counsel’s alleged illness excuse the failure to timely appeal.
  • Substantive Policy Reinstatement
    • Whether the lapsed policy was validly reinstated before Eulogio’s death under the contract and the application terms.
    • Whether Violeta is entitled to death benefits notwithstanding non-approval of the reinstatement.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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