Case Digest (G.R. No. 217120) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Violeta R. Lalican v. The Insular Life Assurance Company Limited, decided on August 25, 2009 under G.R. No. 183526, petitioner Violeta Lalican sought death benefits under Policy No. 9011992 issued by Insular Life to her husband, Eulogio C. Lalican, on April 24, 1997. The 20-Year Endowment Variable Income Package Flexi Plan, with riders, carried a total face value of ₱1,500,000.00 and required quarterly premiums of ₱8,062.00, payable on the 24th of January, April, July, and October, with a 31-day grace period. Eulogio paid the premiums due in July and October 1997 but defaulted on the January 24, 1998 payment. After the grace period expired, the policy lapsed. Eulogio applied for reinstatement on May 26, 1998, submitting one overdue premium but failing to include interest. Upon demand to settle interest and subsequent premiums, he filed a second reinstatement application on September 17, 1998, accompanied by ₱17,500.00, but died later that day. Insular Life did not approve rei Case Digest (G.R. No. 217120) Expanded Legal Reasoning Model
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)