Case Digest (G.R. No. L-2227)
Facts:
Inestate Estate of the Late Esperanza J. Villanueva, Pablo Oro, Administrator; Mariano J. Villanueva, Claimant and Appellant, G.R. No. L-2227. August 31, 1948, the Supreme Court En Banc, Paras, J., writing for the Court.
The dispute arises from two life insurance policies issued by West Coast Life Insurance Company on the life of Esperanza J. Villanueva: one for P2,000 maturing April 1, 1943, and another for P3,000 maturing March 31, 1943. Each policy expressly provided that the company would pay the sum "to the insured hereunder, if living, on [the maturity date], or to the beneficiary Bartolome Villanueva, father of insured, immediately upon receipt of due proof of the prior death of the insured ... during the continuance of this policy," and also reserved to the insured the right to change the beneficiary.
After Bartolome's death in 1940, Mariano J. Villanueva (a brother of the insured) was duly substituted as beneficiary. Esperanza survived both maturity dates but later died on October 15, 1944, without having collected the policy proceeds. Competing claims to the proceeds were filed: the intestate estate of Esperanza (represented by Pablo Oro, administrator) asserted the proceeds belonged to the insured/estate by virtue of Esperanza’s survival to the maturity dates; Mariano claimed entitlement as designated beneficiary.
The conflict was litigated in the Court of First Instance of Iloilo in the intestate estate proceedings of Esperanza. By order dated February 26, 1947, the trial court held that the est...(Subscriber-Only)
Issues:
- Whether the proceeds of the two life insurance policies are payable to the insured (or her estate) because she survived the policies' stated maturity dates, thereby excluding the beneficiary's claim.
- Whether the Court's prior decision in Del Val v. Del Val, 29 Phil. 534, requires that the proceeds belong exclusively to the beneficiary notwithstanding the survival-to-maturity st...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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