Facts:
Stronghold Insurance Company, Incorporated issued Commercial Vehicle Policy No. 279675 covering a Fuso truck, Plate No. PWH 512, owned by
Gloria Dee Chong, with a premium of P15,306.45. While the policy was in effect, the insured vehicle figured in an accident along National Highway in Brgy. Palihan, Hermosa, Bataan on February 12, 1997 that resulted in four deaths, three persons seriously injured, and heavy damage to two other vehicles. Pursuant to the policy,
Interpacific Container Services and
Gloria Dee Chong filed a claim for P550,000.00 composed of Comprehensive Third Party Liability (P50,000.00), Own Damage (P300,000.00), Excess/Bodily Injury (P100,000.00) and Third Party Liability/Property Damage (P100,000.00).
Stronghold Insurance denied the claim on the ground that the driver of the insured vehicle was intoxicated, relying on a Pagpapatunay by Barangay Chairman Rafael Torres and a Medico Legal Certificate signed by Dr. Ferdinand Bautista and invoking in argument the prohibition in
Section 53 of Republic Act No. 4136. The respondents sued in RTC of Caloocan City, Branch 130, docketed as Civil Case No. C-18278, alleging unjust denial and asserting entitlement under the insurance contract. After trial, the RTC rendered judgment in favor of the respondents ordering Stronghold to pay P550,000.00 with twelve percent interest from February 12, 1997, exemplary damages of P50,000.00, attorney’s fees of P100,000.00 and costs; the RTC dismissed petitioner’s counterclaim. On appeal, the Court of Appeals affirmed the RTC’s findings and obligations but deleted the exemplary damages. Petitioner then filed a Petition for Review on Certiorari to the Court contesting the appellate ruling chiefly on the existence of intoxication, the sufficiency of proof, and the propriety of interest.
Issues:
Was it proven at trial that the driver of the insured vehicle was intoxicated at the time of the accident so as to justify avoidance of the insurance policy? Was the petitioner liable to pay the claimed insurance proceeds in the absence of sufficient proof of intoxication? Was the award of interest proper and contrary to law or jurisprudence?
Ruling:
Ratio:
Doctrine: