Title
Multi-Ware Manufacturing Corp. vs. Cibeles Insurance Corp.
Case
G.R. No. 230528
Decision Date
Feb 1, 2021
Multi-Ware's fire insurance claims denied due to non-disclosure of co-insurance policies, violating policy conditions; SC upheld lower courts' rulings.

Case Digest (G.R. No. 126124)
Expanded Legal Reasoning Model

Facts:

  • Parties and Nature of Business
    • Petitioner Multi-Ware Manufacturing Corporation (Multi-Ware) is a domestic corporation engaged in the manufacture of various plastic products.
    • Respondents are insurance companies: Cibeles Insurance Corporation, Western Guaranty Corporation, and Ernesto Sy doing business as "Pan Oceanic Insurance Services."
  • Insurance Policies
    • On December 14, 1999, Multi-Ware took out Fire Policy Insurance No. 50-118320 from Western Guaranty for ₱10,000,000.00 covering machinery, equipment, tools, spare parts, and accessories stored at Buildings 1 and 2, PTA Compound, Valenzuela, Metro Manila.
    • On February 20, 2000, Multi-Ware secured another fire insurance policy from Cibeles Insurance (Policy No. 80-43032) for ₱7,000,000.00 covering machinery, equipment, tools, spare parts, excluding moulds, stocks of manufactured goods, goods in process, raw materials, and supplies located at PTA Central Warehouse Compound, Valenzuela, Metro Manila.
    • Subsequently, Multi-Ware obtained additional fire insurance policies from Prudential Guarantee Corporation covering the same machinery and equipment at Building 1, PTA Compound.
  • Incident and Claims
    • On April 21, 2000, a fire occurred at the PTA Compound damaging the insured properties.
    • Multi-Ware filed claims with Cibeles Insurance and Western Guaranty, which were denied on grounds of violation of Policy Conditions Nos. 3 (non-disclosure of co-insurance), 15 (fraudulent claims), and 21 (arson).
  • Court Proceedings
    • Multi-Ware filed separate civil actions against Cibeles Insurance and Western Guaranty, which were consolidated for trial before the Regional Trial Court (RTC) of Manila.
    • On August 26, 2015, the RTC rendered a Joint Decision dismissing the complaints for lack of merit due to violation of Policy Condition No. 3; counter-claims were also dismissed.
    • The RTC denied Multi-Ware's motion for reconsideration on January 8, 2016.
    • On appeal, the Court of Appeals (CA) affirmed the RTC’s decision and order on November 29, 2016, and denied the motion for reconsideration of Multi-Ware on March 9, 2017.
    • Multi-Ware filed a Petition for Review on Certiorari before the Supreme Court contesting the findings.

Issues:

  • Whether the Court of Appeals erred in holding that petitioner violated Policy Condition No. 3 ("other insurance clause") despite alleged lack of competent evidence.
  • Whether Policy Condition No. 3 applies to the machinery, equipment, and tools covered by the fire insurance policies.
  • Whether petitioner’s failure to disclose the existence of other fire insurance policies covering the same machinery and equipment resulted in forfeiture of benefits under the policies.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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