Case Summary (G.R. No. 183869)
Factual Background
In April 1969, Carmen O. Lapuz applied for accident and injury insurance with the Manila Bankers Life Insurance Corporation. On April 15, 1969, she provided her birth date as July 11, 1904, indicating that she was nearly 65 years old at the time of application. She paid a premium of P20.00, for which she received a receipt, and was subsequently issued Certificate of Insurance No. 128866, effective for 90 days. Carmen died in a vehicular accident while the policy was active.
Claims and Initial Denial
On June 7, 1969, Regina L. Edillon, the named beneficiary and sister of the insured, filed a claim for the insurance proceeds. The insurance corporation denied the claim, citing an exclusion clause in the insurance certificate which nullified coverage for individuals over 60 years of age. The corporation claimed Carmen's age invalidated the insurance contract.
Trial Court Ruling
The trial court sided with the insurance company, ruling that the policy was void due to the insured's non-compliance with the age requirement. It dismissed Regina's complaint, ordered her to pay attorney's fees amounting to P1,000, and mandated the return of the P20 premium to the insurer. The court emphasized that Carmen should have been aware of the policy's terms, thus expecting her to seek a refund rather than enforce the contract.
Supreme Court Decision
The Supreme Court reversed the trial court's judgment, highlighting that the insurer accepted the application with full knowledge of the insured's age, which was stated prominently on the application form. Despite this awareness, the insurance corporation issued the policy and accepted the premium without contest. The Court determined that the insurer's inaction constituted a waiver of the exclusionary age condition, effectively placing it in estoppel.
Legal Precedent and Interpretation
The Court referenced previous rulings, particularly the case of Que Chee Gan vs. Law Union Rock Insurance Co., Ltd., affirming that an insurer cannot assert the nullity of a policy when it had prior knowledge of conditions that would invalidate it. The judgment reiterated that accepting premium payments creates an expectation of a valid insurance contract, and
...continue readingCase Syllabus (G.R. No. 183869)
Case Citation
- Citation: 202 Phil. 508
- Division: First Division
- G.R. No.: L-34200
- Date: September 30, 1982
Legal Question
- The pivotal legal question in this case revolves around whether the acceptance of premiums and the issuance of an insurance certificate by the private respondent insurance corporation constitutes a waiver of the exclusionary condition regarding the age limit stated in the certificate.
Material Facts
- In April 1969, Carmen O. Lapuz applied for insurance coverage against accidents and injuries with the Manila Bankers Life Insurance Corporation.
- On April 15, 1969, she provided her date of birth as July 11, 1904, thereby indicating she was nearly 65 years old.
- She paid a premium of P20.00 for the insurance coverage, receiving a signed receipt from an authorized company agent.
- The insurance corporation issued Certificate of Insurance No. 128866, valid for 90 days.
- Carmen O. Lapuz died in a vehicular accident on May 31, 1969, within the coverage period.
- Regina L. Edillon, the named beneficiary and sister of the insured, filed a claim on June 7, 1969, which was denied by the insurance corporation.
Respondent's Defense
- The Manila Bankers Life Insurance Corporation invoked an exclusionary clause in the insurance certificate, asserting it was not liable for claims involving individu