Title
Sun Life of Canada , Inc. vs. Sibya
Case
G.R. No. 211212
Decision Date
Jun 8, 2016
In the case of Sun Life of Canada (Philippines), Inc. v. Sibya, the Court of Appeals orders the insurer to pay death benefits and damages to the beneficiaries of a life insurance policy, despite the insurer's claim of concealment and misrepresentation by the deceased insured.
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Case Digest (G.R. No. 211212)

Facts:

  • The case involves "Sun Life of Canada (Philippines), Inc. v. Sibya."
  • Respondents: Ma. Daisy S. Sibya, Jesus Manuel S. Sibya III, Jaime Luis S. Sibya, and the Estate of Atty. Jesus Sibya, Jr.
  • On January 10, 2001, Atty. Jesus Sibya, Jr. applied for life insurance with Sun Life.
  • He disclosed past medical advice for kidney problems and a lithotripsy in 1987 for kidney stones.
  • Sun Life approved the application on February 5, 2001, issuing Policy No. 031097335 with a death benefit of P1,000,000.00.
  • Atty. Jesus Jr. died from a gunshot wound on May 11, 2001, in San Joaquin, Iloilo.
  • Ma. Daisy filed a death benefits claim, which Sun Life denied on August 27, 2001, citing non-disclosure of 1994 medical treatments suggesting renal failure.
  • Sun Life refunded the premiums paid.
  • Respondents reiterated their claim; Sun Life refused and filed a Complaint for Rescission in RTC, Makati City, alleging material concealment and misrepresentation.
  • The RTC dismissed Sun Life's complaint on March 16, 2009, ruling no material concealment or misrepresentation, and ordered Sun Life to pay death benefits and damages.
  • The Court of Appeals (CA) affirmed the RTC's decision on November 18, 2013, but absolved Sun Life from charges of violating the Insurance Code.
  • Sun Life's Motion for Partial Reconsideration was denied on February 13, 2014, leading to a petition for review on certiorari before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition for review.
  • The CA's decision was affirmed, indicating no concealment or misrepresentat...(Unlock)

Ratio:

  • Under Section 48 of the Insurance Code, an insurer has two years from the effectivity of a life insurance contract to discover or prove concealment or misrepresentation.
  • If the insured dies within this two-year period, the insurer must fulfill its obligation under the policy regardless of concealment or misrepresentation.
  • Atty. Jesus Jr. died three months after the policy issuance, nullifying Sun Life's right to rescind the policy.
  • The CA found no concealment or misrepresentation by Atty. Jesus Jr. He ...continue reading

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