Case Summary (G.R. No. 100970)
Procedural History
The Insurance Commission found for the complainant and ordered the insurer to pay P15,000 as policy proceeds with legal interest (denying mortuary aid for lack of proof). The Court of Appeals affirmed the Insurance Commission’s decision. The insurer then petitioned the Supreme Court by certiorari, claiming that the appellate court committed grave abuse of discretion in recognizing coverage for death by deliberate assault.
Issue Presented
Whether the insured’s death by stabbing amounted to an “accident” within the meaning of the personal accident policy, and whether the insurer could be discharged from liability by implication because murder or assault were not expressly listed as covered or excluded risks.
Legal Standard on “Accident” and Relevant Precedent
The Court restated the established, ordinary meaning of “accident” and “accidental” in insurance contracts: events happening by chance or fortuitously, without intention or design, unexpected and unforeseen. Quoting De la Cruz, the Court reiterated the rule that a death or injury is not accidental if it is the natural result of the insured’s voluntary act, unless some additional, unexpected, independent, and unforeseen occurrence produces the harm. Conversely, if death results from an unexpected event that the insured did not foresee, it is within the protection of accident policies.
Application of the Accident Doctrine to the Facts
Applying the foregoing rule, the Court accepted the appellate court’s conclusion that the insured did not die as the natural result of any voluntary act by him exposing himself to danger. The record did not establish that the insured provoked or intended the encounter, nor did it show any circumstance indicating that the insured voluntarily assumed the risk. The stabbing occurred while the insured was merely returning home after a public celebration; the incident was an unexpected, unforeseeable attack from the insured’s perspective. Consequently, the death was properly characterized as accidental for purposes of the personal accident policy.
Contract Interpretation and the Principle of Expressio Unius Exclusio Alterius
The personal accident policy expressly enumerated ten specific circumstances that negate insurer liability, but did not list murder or assault among them. The Court applied the principle expressio unius exclusio alterius—the express mention of certain things implies the exclusion of others—to infer that the insurer did not intend to exclude deaths resulting from murder or assault by implication. This inference was reinfor
...continue readingCase Syllabus (G.R. No. 100970)
Procedural Posture
- Petition for certiorari filed by petitioner Finman General Assurance Corporation seeking annulment and setting aside of the Court of Appeals decision dated July 11, 1991, which affirmed the Insurance Commission decision dated March 20, 1990.
- Petitioner also prayed for the issuance of a restraining order and a preliminary mandatory injunction to prevent enforcement of the lower decisions.
- The petition alleged grave abuse of discretion by the Court of Appeals in affirming the Insurance Commission’s order to pay the proceeds of a personal accident insurance policy to private respondent Julia Surposa.
- The Supreme Court denied the petition for certiorari for lack of merit.
Facts
- On October 22, 1986, Carlie Surposa (the deceased) was covered by petitioner Finman General Assurance Corporation under Finman General Teachers Protection Plan Master Policy No. 2005 and Individual Policy No. 08924.
- The record states that Carlie Surposa was insured “with his parents, spouses Julia and Carlos Surposa and brothers Christopher, Charles, Chester and Clifton, all surnamed Surposa, as beneficiaries.” [source phrasing preserved]
- While the policy was in full force and effect, the insured, Carlie Surposa, died on October 18, 1988 from a stab wound inflicted by one of three unidentified men.
- The stabbing occurred without provocation and warning while Carlie and his cousin Winston Surposa were waiting for a ride along Rizal-Locsin Streets, Bacolod City, after attending the celebration of the “Maskarra Annual Festival.”
- The beneficiaries filed a written notice of claim with the petitioner-insurance company, which denied the claim on the ground that murder and assault are not within the scope of the policy’s coverage.
Insurance Policy Details and Exclusions
- The personal accident insurance policy at issue was a master policy (Finman General Teachers Protection Plan Master Policy No. 2005) with an individual policy (No. 08924).
- The policy specifically enumerated only ten (10) circumstances in which no liability would attach to the insurer for any injury, disability, or loss suffered by the insured as a result of the stipulated causes.
- Murder and assault were not expressly enumerated among those prohibited risks in the policy’s list of exclusions.
Claim, Insurance Commission Proceedings, and Relief Awarded
- After the insurer denied the claim, private respondent Julia Surposa filed a complaint with the Insurance Commission on February 24, 1989.
- The Insurance Commission rendered a decision ordering respondent (the insurer) to pay complainant the sum of P15,000.00 representing the proceeds of the policy, with legal interest from the date of the filing of the complaint until fully satisfied.
- The Insurance Commission declined to entertain a claim for mortuary aid in the sum of P1,000.00, noting that no evidence had been submitted to prove that claim.
Court of Appeals Decision
- On July 11, 1991, the Court of Appeals affirmed the Insurance Commission decision ordering payment of the policy proceeds with interest.
- The Court of Appeals’ reasoning, as quoted in the record, emphasized that the insured’s death could not be said to have resulted from the insured’s voluntary act and that the fatal stabbing was, as to the victim, a “pure accident”:
- The insured and his companion were on their way home from a festival and were confronted by unidentified persons.
- The record was barren of any circumstance showing how the stab wound was inflicted.
- It could not be pretended that the malefactor aimed at the insured precisely because the killer wanted to take his life.
- The happening was an event that took place “without his foresight or expectation, an event that proceeded from an unusual effect of a known cause and therefore, not expected.”
Petitioner’s Arguments Before the Supreme Court
- Petitioner contended that the Court of Appeals committed grave abuse of discretion by applying the principle of “expresso unius excl