Case Digest (G.R. No. 175666) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On July 3, 1993, Delia Sotero applied for and obtained Life Insurance Policy No. 747411 from Manila Bankers Life Insurance Corporation, designating her niece, Cresencia P. Aban, as beneficiary. The policy, valued at ₱100,000.00, was issued on August 30, 1993 after medical examination and premium payment. When Sotero died on April 10, 1996—more than two years and seven months after issuance—Aban filed a claim on July 9, 1996. An insurer’s investigation revealed that Sotero was illiterate, infirm since 1990, lacked means to pay premiums, and did not sign the application; it concluded that Aban had procured the policy by impersonation and fraud. On April 16, 1997, the insurer denied the claim and refunded premiums. Eight days later, it filed Civil Case No. 97-867 before the Regional Trial Court of Makati seeking rescission and/or annulment under Presidential Decree No. 612 and Article 1390 of the Civil Code. Aban moved to dismiss on grounds of prescription under Section 48 of the I Case Digest (G.R. No. 175666) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Policy inception and designation
- On July 3, 1993, Delia Sotero applied for and was issued Life Insurance Policy No. 747411 (face value ₱100,000) by Manila Bankers Life Insurance Corporation, naming her niece Cresencia P. Aban as beneficiary.
- The policy became effective on August 30, 1993, following the requisite medical examination and payment of premiums.
- Claim and insurer’s investigation
- Sotero died on April 10, 1996. Aban filed a claim for the proceeds on July 9, 1996.
- Bankers Life conducted an investigation and found that Sotero was illiterate, sickly since 1990, lacked financial means, did not sign the application, and that Aban had posed as Sotero and paid the premiums.
- Denial and rescission suit
- On April 16, 1997, the insurer denied Aban’s claim and refunded the premiums.
- On April 24, 1997, Bankers Life filed Civil Case No. 97-867 for rescission and/or annulment of the policy, alleging fraud, concealment or misrepresentation under the Insurance Code and voidability under Civil Code Article 1390.
- Procedural history
- Aban moved to dismiss on the ground of prescription under Section 48 of the Insurance Code. The Regional Trial Court granted the motion on December 9, 1997, and denied reconsideration on October 20, 1998.
- Bankers Life appealed to the Court of Appeals (CA-G.R. CV No. 62286); the CA affirmed the dismissal on September 28, 2005, and denied reconsideration on November 9, 2006.
- Bankers Life filed this Petition for Review on Certiorari before the Supreme Court.
Issues:
- Whether the Court of Appeals erred in sustaining dismissal on the ground of prescription under Section 48 of the Insurance Code.
- Whether the CA erred in upholding the application of the incontestability provision in Section 48.
- Whether the CA erred in denying petitioner’s motion for reconsideration.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)