Case Digest (G.R. No. 92383)
Facts:
- Sun Insurance Office, Ltd. is the petitioner; Nerissa Lim is the respondent.
- The petitioner issued Personal Accident Policy No. 05687 to Felix Lim, Jr. with a face value of P200,000.00.
- Felix Lim, Jr. died from a bullet wound to the head on October 6, 1982, two months after the policy was issued.
- The incident occurred after a birthday party for his mother.
- Nerissa Lim, the beneficiary, filed a claim for the insurance payout, which was denied by the petitioner.
- The petitioner acknowledged the death was not a suicide but argued it did not qualify as an accident.
- Pilar Nalagon, Lim's secretary, was the only eyewitness; she testified that Lim was in a good mood and playing with his handgun, which he believed was unloaded.
- Despite Nalagon's warning, Lim pointed the gun at his temple, and it discharged, resulting in his death.
- After the claim denial, Nerissa Lim sued in the Regional Trial Court of Zamboanga City, which ruled in her favor.
- The Court of Appeals upheld the decision, leading the petitioner to appeal to the Supreme Court.
Issue:
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Ruling:
- The Supreme Court ruled that Felix Lim, Jr.'s death was an accident covered by the insurance policy.
- The Court found that he did not willfully expose himself to needless peril, so his claim was not barred by the policy's exceptions.
- The Court held tha...(Unlock)
Ratio:
- The Supreme Court defined "accident" in insurance contracts as events occurring unexpectedly and without intention.
- The Court concluded that the death was an accident due to the unforeseen discharge of the gun.
- The petitioner argued that Lim's action of pointing the gun constituted willful exposure to peril; however, the Court noted Lim believed the gun was unloaded and did not act with reckless disregard for his life.
- The distinction was made between willful exposure ...continue reading
Case Digest (G.R. No. 92383)
Facts:
The case involves Sun Insurance Office, Ltd. as the petitioner and Nerissa Lim as the respondent. The events leading to the case began when the petitioner issued Personal Accident Policy No. 05687 to Felix Lim, Jr., with a face value of P200,000.00. Tragically, two months after the policy was issued, Felix Lim, Jr. died from a bullet wound to the head on October 6, 1982, following a birthday party for his mother. Nerissa Lim, as the beneficiary, filed a claim for the insurance payout, which was subsequently denied by the petitioner. The petitioner acknowledged that the death was not a suicide but contended that it did not qualify as an accident either. The only eyewitness to the incident was Pilar Nalagon, Lim's secretary, who testified that Lim was in a good mood and was playing with his handgun, which he had previously unloaded. Despite Nalagon's warning that the gun might be loaded, Lim assured her it was safe. He then pointed the gun at his temple, and moments later, it discharged, resulting in his death. Following the denial of her claim, Nerissa Lim filed a lawsuit in the Regional Trial Court of Zamboanga City, which ruled in her favor, ordering the petitioner to pay the face value of the policy along with additional damages. The decision was upheld by the Court of Appeals, prompting the petitioner to appeal to the Supreme Court, challenging the ruling on the basis of the definitions of "accident" and the exceptions outli...