Case Digest (G.R. No. 92492) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 92492, decided on June 17, 1993 under the 1987 Philippine Constitution, petitioner Thelma Vda. de Canilang sought recovery of life insurance proceeds after the death of her husband, Jaime Canilang, insured under Great Pacific Life Assurance Corporation. On June 18, 1982, Dr. Wilfredo B. Claudio diagnosed Jaime with sinus tachycardia and prescribed Trazepam and Aptin. On August 3, 1982, he treated Jaime for acute bronchitis. Despite these consultations, Jaime applied on August 4, 1982 for a non-medical insurance policy, completed a medical declaration denying any prior hospitalization, medical advice, or treatment for heart or lung conditions, and omitted to list any exceptions. Great Pacific issued Policy No. 345163, face value ₱19,700, effective August 9, 1982. Jaime died of congestive heart failure and chronic anemia on August 5, 1983. When petitioner claimed benefits, the insurer denied the claim on grounds of material concealment. Petitioner appealed to the Insur Case Digest (G.R. No. 92492) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Policy Application
- Jaime Canilang consulted Dr. Wilfredo B. Claudio on 18 June 1982 and was diagnosed with “sinus tachycardia,” prescribed Trazepam and Aptin.
- On 3 August 1982, he was treated for “acute bronchitis.”
- On 4 August 1982, he applied for a non-medical life insurance policy (Policy No. 345163, face value P19,700) with Great Pacific Life Assurance Company, naming his wife Thelma Canilang as beneficiary.
- Death and Claim Denial
- Jaime Canilang died on 5 August 1983 of “congestive heart failure,” “anemia,” and “chronic anemia.”
- Thelma Canilang filed a claim; Great Pacific denied it on 5 December 1983 for concealment of material information.
- Proceedings Before the Insurance Commissioner
- Petitioner testified unawareness of serious illness and thought death due to a kidney disorder.
- Dr. Claudio’s deposition confirmed prior treatment for sinus tachycardia and acute bronchitis.
- Great Pacific’s medical underwriter, Dr. Quismorio, explained non-medical policies waive exams unless applicant indicates prior consultations.
- Insurance Commissioner Ansaldo (5 Nov 1985) ordered payment of P19,700 plus interest and P2,000 attorney’s fees, finding:
- Ailments were not so serious to affect underwriting.
- Great Pacific waived inquiry by issuing policy despite incomplete answers.
- No intentional concealment—insured believed ailments were minor.
- B.P. Blg. 874 (effective 1 June 1985) inapplicable.
- Court of Appeals Decision
- On appeal, CA reversed: held the issue was material concealment, not intent.
- Found failure to disclose prior consultations was material and justified denial.
- Distinguished Ng Gan Zee (misrepresentation) from concealment cases.
- Supreme Court Petition
- Petitioner argued CA erred by ignoring agreed issue of “intentional” concealment and that non-disclosure did not amount to fraud and was waived by insurer.
Issues:
- Nature of Concealment
- Whether the controlling issue was intentional concealment of material health information by the insured.
- Effect of Non-Medical Policy
- Whether Great Pacific waived its right to inquire by issuing a non-medical policy despite incomplete medical declaration.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)