Case Digest (G.R. No. L-48049) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Emilio Tan, Juanito Tan, Alberto Tan and Arturo Tan v. Court of Appeals and Philippine American Life Insurance Company (G.R. No. L-48049, June 29, 1989), petitioners, four sons of the late Tan Lee Siong, applied for an P80,000 life insurance policy with Philippine American Life Insurance Company on September 23, 1973. The company issued Policy No. 1082467 effective November 6, 1973, naming the petitioners as beneficiaries. On April 26, 1975, Tan Lee Siong died of hepatoma, and the petitioners filed a claim for the policy proceeds. On September 11, 1975, respondent insurer denied the claim and rescinded the contract, citing misrepresentation and concealment of material facts by the deceased in his application and refunded all premiums. The petitioners then lodged a complaint with the Office of the Insurance Commissioner on November 27, 1975 (I.C. Case No. 218). After hearings, the Insurance Commissioner dismissed their complaint on August 9, 1977. The petitioners appealed to t Case Digest (G.R. No. L-48049) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Petitioners: Emilio Tan, Juanito Tan, Alberto Tan, Arturo Tan, beneficiaries under Policy No. 1082467.
- Respondents: Court of Appeals and Philippine American Life Insurance Company (PhilAmLife); dispute over recovery of P80,000 life‐insurance proceeds.
- Insurance Application, Issuance, and Claim
- September 23, 1973: Tan Lee Siong applied for P80,000 life policy with PhilAmLife.
- November 6, 1973: Policy No. 1082467 issued, naming petitioners as beneficiaries.
- April 26, 1975: Insured died of hepatoma; petitioners filed claim for proceeds.
- September 11, 1975: PhilAmLife denied claim, rescinded policy for alleged misrepresentation and concealment; refunded premiums.
- Administrative and Judicial Proceedings
- November 27, 1975: Petitioners filed complaint before the Insurance Commissioner (I.C. Case No. 218).
- August 9, 1977: Insurance Commissioner dismissed complaint.
- Petitioners appealed to Court of Appeals; it affirmed the dismissal for lack of merit.
- Petitioners filed this petition for review on certiorari to the Supreme Court.
Issues:
- Rescission Post‐Death
- Can an insurer rescind a life policy after the insured’s death?
- Does Section 48, Insurance Code, limit rescission to the insured’s lifetime and within two years?
- Grounds for Avoidance
- May the insurer avoid the policy on grounds of concealment or misrepresentation by the deceased?
- Is such avoidance contrary to the policy contract or applicable law and jurisprudence?
- Sufficiency of Evidence
- Did the Court of Appeals err in concluding that PhilAmLife was misled by the insured’s concealment?
- Were petitioners prejudiced by alleged non‐presentation of medical examiners or agent witnesses?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)