G.R. No. 211212 - Sun Life of Canada , Inc. vs. Sibya

On January 10, 2001, Atty. Jesus Sibya, Jr. applied for life insurance with Sun Life of Canada (Philippines), Inc., declaring a 1987 kidney lithotripsy under Dr. Mendoza at the National Kidney Institute, with no claimed recurrence.
On February 5, 2001, Sun Life approved the application and issued Policy No. 031097335, naming Ma. Daisy S. Sibya, Jesus Manuel S. Sibya III, and Jaime Luis S. Sibya as beneficiaries, with a P1,000,000 death benefit if death occurred before February 5, 2021.

On May 11, 2001, Atty. Jesus Jr. died from a gunshot wound; Ma. Daisy filed a Claimant’s Statement for the P1,000,000 death benefit.
On August 27, 2001, Sun Life denied the claim for alleged non-disclosure of prior treatment at the National Kidney Transplant Institute in 1994 and refunded premiums instead.

Sun Life filed a Complaint for Rescission before the RTC, alleging concealment of renal-failure treatment in 1994. Respondents countered that the insured acted in good faith and authorized Sun Life to verify his history.
On March 16, 2009, the RTC (Makati, Branch 136) dismissed Sun Life’s complaint, held no material misrepresentation, and ordered payment of P1,000,000 death benefits plus P100,000 moral damages, P100,000 exemplary damages, and P100,000 attorney’s fees and costs.
On November 18, 2013, the CA affirmed the RTC’s award of benefits and damages but absolved Sun Life of violations of Sections 241 and 242 of the Insurance Code; its denial of reconsideration on February 13, 2014 was likewise affirmed.
Sun Life filed a petition for review on certiorari under Rule 45 before the Supreme Court.

Whether the Court of Appeals erred in finding that Atty. Jesus Sibya, Jr. committed no concealment or misrepresentation in his insurance application.
Whether Sun Life lost its right to rescind the policy upon the insured’s death within the two-year contestability period under Section 48 of Presidential Decree No. 612.