Case Digest (G.R. No. 240320)
Facts:
The Philippine American Life and General Insurance (Philam Life) Company and Pablito Bais, petitioners, vs. Romeo D. Soriano and Maria Luisa R. Soriano, respondents, G.R. No. 240320, May 22, 2024, Supreme Court Third Division, Dimaampao, J., writing for the Court.Petitioners are Philam Life (insurer) and Pablito Bais (investigator); respondents are spouses Romeo D. Soriano (insured) and Maria Luisa R. Soriano (his spouse). Romeo was employed as an account executive and held multiple accident insurance policies with several insurers, including two policies from Philam Life (W443343 for PHP300,000 and W443344 for PHP500,000). On January 29, 2001, Romeo allegedly tripped coming out of the bathroom and struck his right eye on a chair armrest; he was examined by Dr. Reynaldo Villanueva, admitted to Manuel J. Santos Hospital, and underwent enucleation of the right eye, incurring medical expenses of PHP31,060.00.
Romeo gave written notices of injury to the insurers; the insurers denied the claims based on a joint affidavit by former household helpers Merced Amor and Rofe Dellera—affidavits obtained by Bais and by Manila Adjusters & Surveyors Company (Philam Life’s credit investigator). In response, spouses Soriano filed separate complaints against Bais and the insurance companies for insurance proceeds, specific performance, damages, and attorney’s fees; the cases (Civil Case Nos. 5119, 5120, 5122, 5136, 5159, and 5160) were consolidated for trial before the Regional Trial Court (Branch 2, Butuan City).
At trial, spouses Soriano and Dr. Villanueva testified for the plaintiffs; Philam Life and Bais presented Dellera and Dr. Mario J. Valenton (a Philam Life–credited physician). The RTC dismissed the complaints applying the equipoise rule. The spouses’ motion for reconsideration was denied by the RTC in an omnibus resolution dated January 21, 2015. The spouses appealed to the Court of Appeals (Special Twenty-Third Division, Cagayan de Oro City), which, in a February 22, 2018 Decision penned by Associate Justice Ruben Reynaldo G. Roxas, reversed the RTC: it found spouses Soriano’s evidence and Dr. Villanueva’s medical findings more credible, concluded the injury was accidental, and ordered the insurers to pay medical reimbursement (PHP31,060.00) and appropriate insurance proceeds for the permanent loss of Romeo’s right eye, with 6% interest from filing of the complaints; the CA, however, dismissed the claims against Bais for lack of proof of malice. Philam Life’s motion for reconsideration in the CA was denied (June 20, 2018).
Philam Life then filed a Petition for Review on Certiorari under Rule 45 to the Supreme Court, arguing (1) the CA erred in finding the injur...(Subscriber-Only)
Issues:
- In a Rule 45 petition, may the Supreme Court review factual findings where the petition raises questions of fact?
- Did the Court of Appeals err in reversing the RTC’s dismissal under the equipoise rule and in finding that spouses Soriano proved by preponderance of evidence that Romeo’s eye injury was accidental, thereby entitling them to insurance proceeds?
- Were spouses Soriano’s testimonies and Dr. Villanueva’s findings improperly relied upon by the CA given allegations that such evidence was self-serving and contradicted by Dr. Valenton’s opinion?
- Should exemplary damages and the modified interest rates ordered by the Supreme Court ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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