G.R. No. 45517 - Trinidad vs. Orient Protective Assurance Association

Plaintiff/Appellee: Tarcila L. Trinidad, widow of Andres Trinidad, and beneficiary of the life insurance benefit.
Defendant/Appellant: Orient Protective Assurance Association, a mutual benefit society incorporated under Philippine laws, engaged in the business of life insurance on a mutual or assessment basis.

Payment of an entrance fee of P6.
Regular contributions of P2 for every death or disability of an ordinary member, with a maximum of twelve contributions per calendar year.

Death within one year from issuance of the certificate entitles the beneficiary to P500.
Death during the second year warrants a benefit of P750.
Death in subsequent years entitles the beneficiary to P1,000.

On February 18, 1935, Andres Trinidad applied for membership and was accepted, receiving a life benefit certificate on the same date.
Andres Trinidad died on January 3, 1936, thereby triggering the benefit claim process by his beneficiary, Tarcila L. Trinidad.

Following Andres Trinidad’s death, Tarcila L. Trinidad promptly notified the defendant about the death and duly accomplished all necessary claim forms.
The completed claim documents were sent to the principal place of business of the defendant in Manila.
The defendant responded by stating that due to the late premium payment by Andres Trinidad, the benefit certificate was forfeited, thereby barring any claim by the beneficiary.

A premium call was mailed to Andres Trinidad on December 1, 1935, providing him a deadline until December 31, 1935 to render payment.
Due to Andres Trinidad’s serious illness, the payment—a money order of P2—was sent on January 2, 1936, and received by the defendant on January 4, 1936.
The defendant’s accountant recorded the payment under the “premium calls” account, indicating acceptance as there was no entry under “suspense account,” which was reserved for doubtful payments.
The payment acceptance, even though rendered late, was not refused or returned by the defendant.

The plaintiff filed the complaint on February 26, 1936, seeking recovery of the sum of P500 with legal interest from the commencement of the action.
The defendant filed its answer on April 2, 1936, which included both a general and specific denial.
After trial, the Court of First Instance of Manila rendered a decision favorable to the plaintiff on September 26, 1936.
The defendant moved for a new trial on October 15, 1936, which was denied on October 24, 1936, and subsequently excepted on November 2, 1936, with an announced intention to appeal.
The plaintiff subsequently moved for the immediate writ of execution of the judgment under Section 144 of the Code of Civil Procedure on November 13, 1936, a petition granted on January 21, 1937.
The case was elevated to the Supreme Court through a bill of exceptions.

Whether the defendant’s acceptance of the late premium payment constituted a waiver of the automatic forfeiture clause in the benefit certificate.

Consideration of whether receiving the P2 payment, despite its tardiness, implied acceptance and hence precluded a forfeiture defense.
Examination of the entry of the payment under “premium calls” rather than “suspense account” as evidence of acceptance.

Whether the cause of death, which the defendant claimed fell within an exclusion that would exempt them from liability, was proven.

Determination of whether any proof was presented that Andres Trinidad died from a cause specifically exempting the defendant from its obligation to pay the benefit.