Case Digest (G.R. No. 253716)
Facts:
Petitioner Platinum Group Metals Corporation (PGMC) purchased Special Risks Policy No. EF-04010/11 from respondent The Mercantile Insurance Co., Inc. covering 100 Sinotruck Howo units for P208,410,988.00 effective August 8, 2011 to August 8, 2012. On October 3, 2011, some three hundred armed persons identifying as members of the CNN raided mining sites in Claver, Surigao del Norte, held employees hostage, fired shots and burned facilities, and destroyed eighty-nine insured trucks; PGMC filed a complaint on August 29, 2013. The RTC rendered judgment for PGMC on November 6, 2017; the CA reversed and dismissed the complaint on December 4, 2019, denied reconsideration on September 25, 2020, and the Supreme Court affirmed the CA with modification by final decision dated July 10, 2023.
Issues:
- Did the Court of Appeals err in concluding that the RTC failed to consider Mercantile’s documentary exhibits and purposes for which they were offered?
- Did the Court of Appeals err in finding that PGMC failed to prove an insurable interest in the insured trucks and in dismissing its claim under the policy?
Ruling:
The petition was denied and the CA Decision and Resolution were affirmed with modification. The Supreme Court held that, under the circumstances, the RTC had in fact considered the parties’ documentary exhibits and that liberality in the rule on formal offer of evidence was appropriate; however, the Court found that PGMC did have an insurable interest in the trucks but that Mercantile proved the proximate cause of loss to be an excepted peril under the policy, thereby relieving Mercantile of liability and justifying dismissal of the complaint.
Ratio:
The Court applied the exception allowing admission of evidence not formally offered where the evidence was identified by testimony and incorporated into the record, noting the RTC repeatedly referred to the parties’ common exhibits and that remand or wholesale exclusion would produce injustice and delay. Under Section 13, Presidential Decree No. 612, insurable interest is not limited to title and was established by PGMC’s possession and substantial economic interest in the trucks; nevertheless, because the policy was an all-risk policy, once PGMC proved loss the burden shifted to Mercantile to prove the loss arose from an excepted peril, which it did by showing the simultaneous, violent, and politically motivated raids constituted insurrection or rebellion within the ordinary meaning of those terms.
Doctrine:
- Formal offer of evidence may be relaxed where the evidence was identified by testimony and incorporated into the records, and where strict application would impede justice.
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