Case Digest (G.R. No. 95252) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In UCPB General Insurance Co., Inc. v. Masagana Telamart, Inc., G.R. No. 137172, decided on April 4, 2001 under the 1987 Constitution, petitioner UCPB issued five fire insurance policies to respondent Masagana covering properties in Pasay City and Manila from May 22, 1991 to May 22, 1992. On June 13, 1992, one of the insured buildings was razed by fire. On July 13, 1992, Masagana tendered five Equitable Bank manager’s checks totaling ₱225,753.95 as renewal premiums, which UCPB accepted and for which official receipts were issued. The next day Masagana formally demanded indemnity, prompting UCPB to return the checks on grounds that (a) the policies had expired on May 22, 1992 without renewal, (b) valid notice of non-renewal had been sent at least 45 days before expiration, and (c) the fire occurred before payment of the renewal premiums. Masagana then filed suit. The trial court allowed Masagana to consign the premium, declared the replacement-renewal policies effective from May Case Digest (G.R. No. 95252) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Insurance coverage and fire loss
- Masagana Telamart, Inc. obtained from UCPB General Insurance five fire insurance policies (Exhs. A–E) covering its Pasay and Manila properties, effective 4:00 PM of 22 May 1991 to 4:00 PM of 22 May 1992.
- A fire razed the Pasay City properties on 13 June 1992.
- On 13 July 1992, Masagana tendered five Equitable Bank manager’s checks totaling P225,753.45 as renewal premiums; UCPB issued Official Receipt No. 62926.
- On 14 July 1992, Masagana made formal demand for indemnity; UCPB returned the checks, rejecting the claim on grounds that (a) the policies expired 22 May 1992 and were not renewed, (b) non-renewal notice was given, and (c) the fire occurred before premium tender.
- Proceedings and lower courts’ findings
- Trial court held the policies renewed by implied credit term, allowed Masagana to consign P225,753.95 as full payment, declared new coverage from 22 May 1992 to 22 May 1993, and awarded P18,645,000 indemnity plus 25% attorney’s fees.
- Court of Appeals affirmed with modification:
- Deleted finding of coverage Aug 1991–Aug 1992 for three policies.
- Reduced attorney’s fees award from 25% to 10%.
- Both courts found UCPB had long granted a 60–90-day credit term for renewal premiums and failed to give valid 45-day non-renewal notice under Policy Condition No. 26.
Issues:
- Main issue
- Whether the fire insurance policies covering 22 May 1991–22 May 1992 were renewed by an implied credit arrangement despite actual payment occurring after the fire risk had materialized.
- Subsidiary issues
- Whether UCPB’s consistent practice of granting 60–90-day credit and accepting late payments estops it from denying renewal.
- Whether UCPB complied with the 45-day advance notice requirement of Policy Condition No. 26 to validly refuse renewal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)