Case Digest (G.R. No. 126124) Core Legal Reasoning Model
Facts:
In the case of Multi-Ware Manufacturing Corporation v. Cibeles Insurance Corporation, Western Guaranty Corporation, and Ernesto Sy, petitioner Multi-Ware Manufacturing Corporation, a domestic manufacturer of plastic products, insured its properties through multiple fire insurance policies in 1999 and 2000. On December 14, 1999, Multi-Ware obtained Fire Policy Insurance No. 50-118320 from Western Guaranty Corporation for ₱10,000,000 covering machinery, equipment, tools, spare parts, and accessories stored at Buildings 1 and 2 of the PTA Compound in Valenzuela, Metro Manila. Later, on February 20, 2000, it secured another fire insurance policy from Cibeles Insurance Corporation (Fire Insurance Policy No. 80-43032) for ₱7,000,000, covering similar items excluding molds as well as stocks of manufactured goods, raw materials, and supplies located at the PTA Central Warehouse Compound. Multi-Ware also procured fire insurance from Prudential Guarantee Corp. for the same machinery and
...
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)