Case Digest (G.R. No. 105562)
Facts:
Luz Pineda, Marilou Montenegro, Virginia Alarcon, Dina Lorena Ayo, Celia Calumbag and Lucia Lontok v. Hon. Court of Appeals and The Insular Life Assurance Company, Ltd., G.R. No. 105562, September 27, 1993, Supreme Court First Division, Davide, Jr., J., writing for the Court.
The petitioners were designated beneficiaries under Group Policy No. G-004694 procured by Prime Marine Services, Inc. (PMSI) from Insular Life Assurance Company, Ltd. following the deaths of six PMSI seamen when M/V Nemos sank on February 17, 1986. On 20 September 1989 the petitioners filed an administrative complaint (IC Case No. RD-058) with the Insurance Commission, seeking payment of their insurance claims and imposition of sanctions against Insular Life for alleged contractual and Insurance Code violations.
Insular Life moved to dismiss for lack of Insurance Commission jurisdiction under Section 416 of the Insurance Code on the ground that some claims exceeded P100,000; the Commission denied the motion (Order of 14 November 1989). Insular Life answered (5 December 1989), and hearings followed. The Commission rendered judgment on 20 June 1990 ordering Insular Life to pay fines, to settle the claims of Dina Ayo (P50,000) and Lucia Lontok (P40,000), to notify beneficiaries in future, and to show cause why certain officers should not be disciplined. The Commission found among other things that (a) five purported special powers of attorney in favor of Capt. Rosendo Nuval did not clearly authorize him to collect insurance proceeds; (b) Insular Life released checks to PMSI without observing Section 180 of the Insurance Code regarding minors; and (c) the company was negligent in releasing the checks.
Insular Life appealed to the Court of Appeals (docketed CA-G.R. SP No. 22950). The Court of Appeals on 10 October 1991 modified the Insurance Commission decision by eliminating the awards to Dina Ayo (P50,000) and Lucia Lontok (P40,000). The CA found that the powers of attorney were sufficiently broad to permit Capt. Nuval to collect and that PMSI (through Capt. Nuval) acted as administrator in the usual course of group insurance dealings, such that the company reasonably relied on the authorizations; it also concluded that Article 225 of the Family Code effectively amended the relevant paragraph of Section 180, Insurance Code, permitting parents to receive minor children’s shares where the share ...(Subscriber-Only)
Issues:
- Did the Insurance Commission have jurisdiction to entertain IC Case No. RD-058 despite some claims exceeding P100,000?
- Whether the special powers of attorney executed by the petitioners authorized Capt. Rosendo Nuval to collect and receive the insurance proceeds on their behalf.
- Whether Insular Life is liable for releasing checks to PMSI/Capt. Nuval under agency/administrator principles applicable to group insurance.
- Whether the mothers of minor beneficiaries could validly receive their children’s shares without court appointment or bond under Section 180 of the ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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