Case Digest (G.R. No. 228402) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Loyola Life Plans, Inc. (now Loyola Plans Consolidated Inc.) engaged in pre-need memorial and pension contracts secured insurance benefits through a Group Creditors Life Insurance Agreement (Master Policy No. GCL-878) with ATR Professional Life Assurance Corporation (now Asian Life and General Assurance Corporation), effective June 15, 1999. On April 28, 2000, Dwight L. Lumiqued purchased a Timeplan from Loyola and paid the first monthly installment of ₱5,040: two Metrobank checks totaling ₱3,424.75 and cash of ₱1,615.25. Loyola’s agent issued an Official Receipt valid for downpayment only and delivered a pre-signed Timeplan contract. The same day, the checks were deposited; the cash was deposited only on May 2, 2000. On May 1, 2000, Dwight died from multiple stab wounds. His widow, Angelita D. Lumiqued, filed a claim for the insurance proceeds, but ATR denied liability on grounds of incomplete premium payment and alleged forgery of Dwight’s signature. ATR then sued to void Dwig Case Digest (G.R. No. 228402) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and antecedents
- Loyola Life Plans Inc. (now Loyola Plans Consolidated Inc.) is a pre-need company offering Timeplan (pension) and Lifeplan (memorial service) contracts, insured by ATR Professional Life Assurance Corporation (formerly GE Life).
- On June 8, 1999, Loyola applied with ATR for a Group Creditors Life Insurance plan (Master Policy No. GCL-878) with supplementary Group Yearly Renewable Term Life and Accidental Death benefits, effective June 15, 1999.
- Dwight L. Lumiqued’s Timeplan
- On April 28, 2000, Dwight purchased a Loyola Timeplan payable in 120 monthly installments of ₱5,040. He paid via two Metrobank checks (₱2,824.75 and ₱600) and cash (₱1,615.25). An Official Receipt stated the payment was valid for downpayment only, subject to check clearance.
- The checks were deposited on April 28; the cash was deposited on May 2; Dwight died on May 1, 2000 from multiple stab wounds.
- Claim denial and procedural history
- Angelita Lumiqued, as beneficiary, filed a claim. ATR denied it on April 17, 2001, citing incomplete premium payment and alleging forgery of Dwight’s application.
- ATR filed suit to void Dwight’s coverage; Loyola (and Angelita by adoption) counterclaimed for benefits and damages.
- The Regional Trial Court (RTC) on July 7, 2011, held coverage effective April 28, 2000, dismissed ATR’s complaint, and awarded ₱1,809,360 actual damages, ₱100,000 moral damages, ₱100,000 exemplary damages, ₱100,000 attorney’s fees, plus costs.
- On February 4, 2016, the Court of Appeals (CA) affirmed policy effectivity but reduced benefits to ₱992,000 and deleted all damage awards. Both parties filed separate petitions to the Supreme Court, later consolidated.
Issues:
- Authenticity of signature
- Was Dwight’s Timeplan application signature forged?
- Perfection of insurance contract
- Did the initial payment on April 28, 2000 perfect the insurance contract, entitling beneficiaries to proceeds?
- Coverage of risk
- Is Dwight’s death from stab wounds a covered peril or excluded as “murder or provoked assault”?
- Entitlement to benefits
- Does the contract entitle the beneficiary to Group Creditors Life Insurance and Group Yearly Renewable Term Life benefits?
- Damages awards
- Did the CA correctly delete the awards of moral damages, exemplary damages, and attorney’s fees?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)