Case Digest (G.R. No. 78860) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Perla Compania de Seguros, Inc. v. Milagros Cayas, petitioner Perla Compania de Seguros, Inc. (“PCSI”) issued an insurance policy (No. LT0/60CC-04241) on February 3, 1978 covering respondent Milagros Cayas’s Mazda passenger bus (Serial No. TA3H4 P-000445, Plate No. PUB-4G-593). On December 17, 1978, the bus was involved in an accident in Naic, Cavite, injuring four passengers. One, Edgardo Perea, filed Civil Case No. NC-794 before the Court of First Instance of Cavite, Branch I, where Cayas defaulted and was ordered to pay P10,000 compensatory, P10,000 exemplary, P5,000 moral damages and P7,000 attorney’s fees. The other three passengers—Rosario del Carmen, Ricardo Magsarili and Charlie Antolin—accepted P4,000 each by way of settlement from Cayas without PCSI’s written consent. Cayas first sought relief from the Insurance Commissioner, then filed Civil Case No. N-4161 in the CFI of Cavite praying that PCSI cover P50,000 plus attorney’s fees. After procedural skirmishes, the t Case Digest (G.R. No. 78860) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Insurance Contract
- Private respondent Milagros Cayas was the registered owner of a Mazda bus (serial no. TA3H4P-000445, plate PUB-4G-593).
- The bus was insured with petitioner Perla Compania de Seguros, Inc. (PCSI) under Policy No. LT0/60CC-04241 issued on February 3, 1978.
- Accident and Initial Claims
- On December 17, 1978, the bus met an accident in Naic, Cavite, injuring several passengers.
- One injured passenger, Edgardo Perea, sued Cayas for damages (CFI Cavite, Civil Case No. NC-794); three others (Rosario del Carmen, Ricardo Magsarili, Charlie Antolin) settled with Cayas for ₱4,000 each.
- Proceedings Against Insured and Insurer
- In Civil Case No. NC-794, Cayas defaulted; the trial court awarded Perea ₱10,000 compensatory, ₱10,000 exemplary, ₱5,000 moral damages, ₱7,000 attorney’s fees.
- Cayas sought recourse from PCSI before the Insurance Commissioner but later withdrew the complaint.
- On November 11, 1981, Cayas filed Civil Case No. N-4161 against PCSI in the CFI Cavite claiming ₱50,000 for all accident-related liabilities plus fees; the case was dismissed for failure to prosecute, then reinstated on reconsideration.
- A default judgment awarded Cayas ₱50,000 compensation, ₱5,000 moral damages, ₱5,000 attorney’s fees; PCSI successfully moved to set aside.
- After trial, the CFI rendered judgment awarding Cayas ₱50,000 total and ₱5,000 attorney’s fees.
- The Court of Appeals affirmed the CFI decision in toto.
- PCSI filed a petition for certiorari before the Supreme Court, challenging its liability under the policy.
Issues:
- Extent of Insurer’s Liability
- Whether PCSI is liable for the full ₱50,000 award to Cayas or only for amounts actually paid by her to injured passengers.
- Whether PCSI’s liability is limited to ₱12,000 per person and ₱50,000 per accident under the policy.
- Effect of Policy Condition Requiring Insurer’s Written Consent
- Whether Cayas may recover reimbursements for the ₱4,000 payments to the three settling passengers despite failing to secure PCSI’s written consent.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)