Case Summary (G.R. No. 47593)
Facts of the Case
Evaristo Feliciano signed an insurance application on October 12, 1934, despite being informed by Dr. Trepp, the examining physician, that he was in a serious medical condition. The application contained a question regarding previous lung ailments, to which Feliciano allegedly answered "No." The petitioner claimed this answer was submitted by the company's soliciting agent, Romulo M. David, in collusion with the medical examiner, Dr. Gregorio Valdez, who were motivated by a sales contest incentive provided by the company.
Stipulations in Insurance Policies
The insurance policies included significant stipulations establishing a framework for the contractual obligations between the parties. Notably, they clarified that the application and the policy formed the entire contract, specifying that only authorized company officials had the power to bind the company in writing. The applicant’s declarations were stated to be the basis of the policy.
Petitioner’s Arguments
The petitioner argued that the policies were null and void ab initio, asserting the respondents were entitled only to a refund of premiums paid. They contended that Feliciano’s failure to disclose his medical condition and that providing false answers should render him and his beneficiaries unable to claim benefits under the policies.
Judicial Reasoning
The majority opinion concluded that Evaristo Feliciano, by signing the application—even if in blank—made the agent and medical examiner his representatives for accurate responses, thus holding him accountable for their misrepresentations. Despite being aware of his failing health and condition, Feliciano accepted the policies and thus assumed knowledge of the application’s content.
Conclusion of the Case
In its decision, the court reversed the previous judgment of the Court of Appeals, ruling in favor of the respondents but allowing only a refund of premium payments amounting to P1,389 with legal interest. The decision emphasized Feliciano’s complicity in the misconduct regarding the application and subsequent representations made by the agents, reinforcing the principle that individuals bear responsibility for the truths they assert in contractual agreements, especially when they are party to fraudulent actions.
Concurring and Dissenting Opinions
Chief Justice Yulo concurred with the majority, emphasizing the necessity for accountability in insurance practices, while Justice Hontiveros dissented, arguing that Feliciano should not be held liable f
...continue readingCase Syllabus (G.R. No. 47593)
Case Overview
- The case involves a dispute between The Insular Life Assurance Company, Ltd. (petitioner) and Serafin D. Feliciano et al. (respondents) regarding the validity of two insurance policies issued on the life of Evaristo Feliciano.
- The Supreme Court of the Philippines, in a four-to-three decision, affirmed the judgment of the Court of Appeals in favor of the respondents on September 13, 1941, awarding them the sum of P25,000.
- The petitioner filed a motion for reconsideration which prompted a detailed examination of the case facts and legal arguments.
Facts of the Case
- Evaristo Feliciano signed an insurance application on October 12, 1934, while suffering from advanced pulmonary tuberculosis.
- Doctor Trepp informed Dr. Serafin D. Feliciano that Evaristo was in a serious and hopeless condition on the same day.
- Despite this, Evaristo answered "No" to a question about prior lung ailments, with the answers being recorded by the Company's soliciting agent, Romulo M. David, in collusion with Medical Examiner Dr. Gregorio Valdez.
- Evaristo's mother provided money for a bribe to facilitate the approval of the insurance application to boost the agent's sales.
Contractual Provisions
- The insurance policies contained stipulations outlining that they, along with the application, constituted the entire contract.
- It specified that only certain high-ranking officials of the Company could modify the contract, and that the agent had