Title
Reyes vs. Insular Life Assurance Co., Ltd.
Case
G.R. No. 180098
Decision Date
Apr 2, 2014
A dispute over the denial of a claim for death benefits by Insular Life Assurance Co., Ltd. leads to a legal battle where the Supreme Court denies the petitioners' request for execution pending appeal, stating that the issue has become moot and academic.
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Case Digest (G.R. No. 180098)

Facts:

  • On September 9 and 16, 1998, Joseph Fauni Reyes obtained two life insurance policies from Insular Life Assurance Company, Ltd. (Insular Life).
  • The beneficiaries were his mother, Ofelia Fauni Reyes, and his brother, Noel Fauni Reyes.
  • The policies, issued in September and October 1998, had a combined face value of P8,000,000.00.
  • On October 19, 1998, a charred body was found inside the trunk of a burnt BMW car owned by Joseph in Ternate, Cavite.
  • Believing the body to be Joseph's, the petitioners filed a claim for death benefits.
  • Insular Life denied the claim on September 30, 1999, citing misrepresentation and concealment of material facts by Joseph.
  • On October 6, 1999, Insular Life filed a complaint for rescission of the insurance contracts and damages before the RTC of Makati, Branch 57.
  • Insular Life alleged that Joseph's death was not sufficiently established and that he had concealed threats to his life and other life insurance policies.
  • The RTC dismissed the complaint on March 8, 2006, for insufficiency of evidence, ordering Insular Life to pay the petitioners the face value of the policies, moral and exemplary damages, and attorney's fees.
  • Insular Life appealed, and the petitioners moved for execution pending appeal, which the RTC granted.
  • Insular Life sought to nullify the writ of execution before the Court of Appeals (CA), which ruled in favor of Insular Life, annulling the writ.
  • The petitioners' motion for reconsideration was denied, leading them to file the present petition before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition, stating that the issue had become moot and academic with the e...(Unlock)

Ratio:

  • The Supreme Court explained that an actual case or controversy is a prerequisite for the court's exercise of its power of adjudication.
  • A justiciable controversy must be definite and concrete, involving legal rights or claims that are ripe for judicial resolution.
  • In this case, the issue of discretionary execution pending appeal had become moot and academic due to the finality of the judgment in G.R. No. 189605, which affirmed the lower courts' rulin...continue reading

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