Title
Rami vs. QBE Insurance Philippines, Inc.
Case
G.R. No. 165855
Decision Date
Oct 31, 2007
A legal conflict ensues over insurance proceeds between Lavine Loungewear Mfg. Inc., insurance companies, and a bank, resulting in administrative liability linked to the execution of a writ against a non-party insurer.
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Case Digest (G.R. No. 165855)

Facts:

  • Lavine Loungewear Mfg. Inc. (Lavine) is a corporation that manufactures and exports loungewear.
  • Lavine procured six fire insurance contracts from various insurers, including Philippine Fire and Marine Insurance Corporation and others.
  • A fire on August 1, 1998, in Pasig City destroyed two of Lavine's buildings and their supplies.
  • Lavine filed claims with the insurers, resulting in a total payable amount of P112,245,324.34 as determined by the Office of the Insurance Commission.
  • Most insurance policies were endorsed to Equitable PCI Bank due to loans taken by Lavine through Harish Ramnani.
  • Insurers were willing to release payments to Equitable Bank, supported by Harish.
  • On March 17, 2000, Lavine's board appointed Chandru Ramnani as president, who demanded direct payment to Lavine.
  • Insurers insisted on paying Equitable Bank, leading Lavine to file a complaint on January 22, 2001, in the RTC of Pasig City.
  • The RTC ruled in favor of intervenors claiming Harish was not validly elected and that Lavine owed Equitable Bank around P71 million.
  • The RTC dismissed Lavine's complaint and ordered insurers to pay the intervenors damages.
  • A motion for execution pending appeal was granted, leading to a writ of execution against QBE Insurance Philippines, Inc., which claimed to be separate from Rizal Surety.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the RTC erred in ordering execution pending appeal against QBE Insurance Philippines, Inc. since it was not a party to the original case.
  • The actions of the RTC and the sheriff in executing th...(Unlock)

Ratio:

  • The Supreme Court emphasized that execution can only be issued against parties to a judgment; thus, the RTC's orders were null and void regarding QBE Insurance.
  • The Court of Appeals correctly found that the sheriff's claims abo...continue reading

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