Case Digest (G.R. No. 54216)
Facts:
The Philippine American Life Insurance Company v. Honorable Gregorio G. Pineda and Rodolfo C. Dimayuga, G.R. No. 54216, July 19, 1989, Supreme Court Second Division, Paras, J., writing for the Court.Petitioner The Philippine American Life Insurance Company issued an ordinary life policy to private respondent Rodolfo C. Dimayuga on January 15, 1968, in which Dimayuga designated his wife and children as irrevocable beneficiaries. In 1980 Dimayuga (the insured) filed a petition in the Court of First Instance of Rizal, docketed as Civil Case No. 9210 (also referred to as Sp. Proc. No. 9210), seeking to amend the policy designation from irrevocable to revocable.
On March 10, 1980 petitioner filed an Urgent Motion to Reset Hearing and a Comment/Opposition to the petition. When the matter was called for hearing on March 19, 1980, respondent Judge Gregorio G. Pineda, presiding judge of the Court of First Instance of Rizal, denied petitioner's Urgent Motion and permitted Dimayuga to adduce evidence, after which the trial court issued an order granting the petition to change the beneficiaries' designation. Petitioner moved for reconsideration, which the trial court denied on June 10, 1980.
Petitioner brought the present action as a petition for review on certiorari to the Supreme Court challenging the trial court's March 19, 1980 and June 10, 1980 Orders that granted Dimayuga's petition and denied reconsideration. The underlying factual points not controverted below included the policy's Beneficiary Designation Indorsement expressly stating the beneficiaries' designatio...(Pro-only)
Issues:
- Whether the designation of irrevocable beneficiaries in a life insurance policy may be changed or amended without the consent of all the irrevocable beneficiaries.
- Whether the (surviving) irrevocable beneficiaries, several of whom were minors and one deceased, could validly give consent to change the designation from ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)