Case Digest (G.R. No. 194328)
Facts:
Respondents Interpacific Container Services and Gloria Dee Chong brought a petition against the petitioner Stronghold Insurance Company, Incorporated regarding an insurance claim following an accident involving a Fuso truck owned by Gloria Dee Chong. The truck, insured under Commercial Vehicle Policy No. 279675 with a premium of P15,306.45, was involved in an accident on the National Highway in Brgy. Palihan, Hermosa, Bataan, which resulted in the death of four individuals and serious injuries to three others. The collision also caused significant damage to two other vehicles. Respondent Chong subsequently filed a claim for insurance proceeds totaling P550,000.00, itemized as follows: P50,000.00 for Comprehensive Third Party Liability, P300,000.00 for Own Damage, P100,000.00 for Excess/Bodily Injury, and P100,000.00 for Third Party Liability. However, the insurance company denied this claim, asserting that the driver of the insured vehicle was intoxicated at the time of the acciCase Digest (G.R. No. 194328)
Facts:
- Background of the Case
- Stronghold Insurance Company, Incorporated (petitioner) is contesting a decision that ordered it to pay an insurance claim.
- The claim involves a Commercial Vehicle Policy (Policy No. 279675) covering a Fuso truck owned by respondent Gloria Dee Chong, evidenced by the vehicle’s Plate No. PWH 512.
- The Insurance Policy and Accident Details
- The insurance policy, worth P15,306.45 in premium, insured the vehicle against losses and third-party liabilities including death and bodily injury.
- An accident occurred along the National Highway in Brgy. Palihan, Hermosa, Bataan, which resulted in:
- The death of four (4) persons.
- Serious injuries to three (3) individuals.
- Heavy damage to two (2) vehicles.
- The Insurance Claim
- Respondents Interpacific Container Services and Gloria Dee Chong filed a claim for the sum of P550,000.00, computed as follows:
- Comprehensive Third Party Liability (CTPL): P50,000.00
- Own Damage (OD): P300,000.00
- Excess / Bodily Injury (BI): P100,000.00
- Third Party Liability (TPL): P100,000.00
- The claim was based on the policy’s commitment to indemnify the insured in cases of accident.
- Grounds for Claim Denial by the Petitioner
- The insurance company denied the claim on the basis that the driver of the insured vehicle was heavily intoxicated at the time of the accident.
- Evidence cited by the petitioner included:
- A Pagpapatunay issued by Barangay Chairman Rafael Torres.
- A Medico Legal Certificate signed by Dr. Ferdinand Bautista.
- Petitioner argued that the intoxication constituted a violation of Section 53 of Republic Act No. 4136 (the Land Transportation and Traffic Code), which bars driving under the influence.
- Trial Court Proceedings and Decision
- Respondents filed an action in the RTC of Caloocan City, alleging the unjust denial of their valid insurance claim.
- During trial:
- Both parties presented testimonial and documentary evidence.
- Matters in dispute centered on whether there was sufficient proof of intoxication.
- On October 7, 2003, the RTC rendered a decision in favor of the respondents, ordering the payment of the sum of P550,000.00 along with additional costs and attorney’s fees.
- The RTC also awarded exemplary damages of P50,000.00, which was later modified by the Court of Appeals.
- Appellate and Certiorari Proceedings
- The Court of Appeals affirmed the RTC’s findings but deleted the award for exemplary damages.
- The appellate court held that the evidence presented by the petitioner regarding intoxication was hearsay and lacked sufficient probative value, particularly noting the absence of any mention in the official police blotter report.
- Petitioner raised several arguments in its Petition for Certiorari, contesting:
- The disregard of clear evidence indicating the driver’s intoxication.
- The sufficiency of proof on the part of respondents.
- The imposition of interest, claiming it was contrary to law and jurisprudence.
Issues:
- Whether the trial court and the Court of Appeals properly assessed the evidence regarding the intoxication of the driver of the insured vehicle.
- Did the petitioner meet its burden to prove that the insured driver was intoxicated at the time of the accident?
- Was the evidence presented sufficient and credible to justify the petitioner’s claim for avoidance of the insurance policy?
- Whether the denial of the insurance claim by the petitioner can be sustained under the terms of the insurance policy and relevant statutory provisions.
- Is the alleged driver's intoxication a valid ground for avoiding the insurance policy under Section 53 of Republic Act No. 4136?
- Does the absence of reference to intoxication in the police blotter report undermine the petitioner’s evidence?
- Whether the imposition of interest and other ancillary awards (like attorney’s fees) was in accordance with applicable law and precedent.
- Was the addition of interest contrary to established jurisprudence?
- Did the evidentiary shortcomings impact the decision to award attorney’s fees against the petitioner?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)