G.R. No. 170656 - Metropolitan Manila Development Authority vs. Viron Transportation Co., Inc.

Platinum Group Metals Corporation (PGMC) is a mining company engaged in exploration, development, processing, and marketing of nickel ore and related products.
PGMC secured an all-risk Special Risks Insurance Policy from The Mercantile Insurance Co., Inc. (Mercantile) covering 100 brand new Sinotruck Howo 6x4 Tipper LHD trucks valued at P208,410,988, effective from noon August 8, 2011, to noon August 8, 2012.

On October 3, 2011, about 300 armed persons identifying as members of the Communist Party of the Philippines/New People’s Army/Nationalist Democratic Front (CNN) simultaneously raided and took control of three mining sites in Claver, Surigao del Norte, including PGMC’s plant site.
PGMC employees and security personnel were held hostage and subjected to public denunciations for environmental destruction, refusal to pay revolutionary taxes, and political grievances.
During the attack, the CNN members fired shots and burned PGMC’s facilities, equipment, and vehicles, resulting in the total destruction of 89 of the insured trucks.

PGMC promptly requested its insurance broker to assess and validate damages for claim processing.
Over nine months passed without claim resolution; PGMC demanded payment of the full insurance amount.
Mercantile denied PGMC’s claim, stating damage was due to "riot, civil commotion, insurrection, and rebellion"—all excluded risks under the insurance policy.

PGMC filed a complaint for breach of obligation and recovery of insurance proceeds plus interest, attorney’s fees, and costs.
Mercantile countered denying insurable interest by PGMC and invoked policy exclusions.
Extensive trial with several witnesses and documentary exhibits; the RTC admitted some evidence but excluded certain exhibits due to procedural issues.

RTC ruled in favor of PGMC, awarding P183,260,779.32 for the damaged trucks, rejecting Mercantile’s claim that damage arose from excluded perils.
RTC held ambiguous policy terms are liberally construed in favor of the insured.
The court ordered legal interest and attorney’s fees; resolved that Mercantile breached obligations under the policy.

Mercantile appealed; the CA reversed the RTC decision, finding PGMC failed to prove insurable interest as ownership documents were mere photocopies and thus inadmissible under best evidence rule.
The CA also noted that the RTC failed to rule on Mercantile’s Formal Offer of Evidence, leading to lack of proper consideration of Mercantile’s evidence.
The CA dismissed PGMC’s complaint.
PGMC’s motion for reconsideration was denied.

PGMC contended the RTC did consider Mercantile’s evidence and that the CA wrongfully found lack of insurable interest and undue procedural fault.
Mercantile maintained PGMC had no insurable interest and that losses were due to excepted risks.
Arguments included the nature and effect of formal offer of evidence and evidentiary burdens.

Whether the Court of Appeals erred in reversing the RTC decision on the ground that the RTC did not consider the formal offer of evidence submitted by Mercantile.
Whether PGMC failed to prove its insurable interest over the insured trucks.
Whether the cause of loss to the insured trucks falls under excepted risks such as riot, civil commotion, insurrection, or rebellion under the insurance policy, thereby excluding Mercantile’s liability.