G.R. No. 183526 - Lalican vs. Insular Life Assurance Co. Ltd.

April 24, 1997: Policy No. 9011992 issued in favor of insured Eulogio C. Lalican, naming Violeta as primary beneficiary. Quarterly premiums of ₱8,062.00 due each January 24, April 24, July 24, and October 24; 31-day grace period applies.
January 24, 1998: Premium unpaid within grace period; policy lapsed and became void on February 24, 1998.
May 26, 1998: First Application for Reinstatement filed with Insular Life, paying only overdue premium but not accrued interest (₱322.48).
July 17, 1998: Insular Life requested payment of interest and new application for reinstatement, plus subsequent premiums with interest.
September 17, 1998 morning: Second Application for Reinstatement filed through Malaluan with deposit of ₱17,500.00 covering overdue interest and premiums due April and July 1998.
September 17, 1998 afternoon: Insured’s death by electrocution.
September 18–21, 1998: Insular Life learned of death; did not process reinstatement application.
September 28, 1998: Violeta filed claim for full policy proceeds. Insular Life denied claim on January 14, 1999, refunding ₱25,417.00 (contributions without interest).

October 11, 1999: Violeta filed Civil Case No. 2177 in RTC Gapan City for death benefits (₱1,500,000.00 plus interest, attorney’s fees).
Answer and counterclaim by Insular Life asserted policy void for non-payment and invalid reinstatement.
Trial culminated in RTC Decision (August 30, 2007) dismissing Violeta’s claim, finding no automatic reinstatement and no authority vested in agent to approve application post-mortem.
Motion for Reconsideration denied (November 8, 2007).
Orders (April 10 & July 3, 2008) declared RTC decision final and denied belated notice of appeal.
August 25, 2009: Supreme Court resolution of Petition for Review on Certiorari under Rule 45, raising procedural and substantive issues.

Whether the Supreme Court may review a final RTC decision absent a timely appeal.
Whether the RTC erred in interpreting the policy and reinstatement provisions to deny death benefits.
Whether insured’s insurable interest under Section 19 of the Insurance Code sufficed to revive the policy upon deposit.

Procedural Finality: 1987 Constitution grants courts jurisdiction only over non-final judgments. Violeta failed to file a notice of appeal within the 15-day reglementary period after receipt of the RTC order (December 3, 2007), filing instead on May 20, 2008. Her counsel’s health issues were unsupported; client is bound by counsel’s negligence. The RTC decision became final and executory; no appeal lay from an order dismissing an appeal (Rule 41, Section 1(c)).
Reinstatement Conditions: Under Insurance Code jurisprudence and Policy provisions, reinstatement of a lapsed life policy requires:
• Approval of application by insurer during insured’s lifetime and good health
• Payment of overdue premiums with interest and evidence of insurability
• Action by authorized officer, not mere agent receipt
Application for Reinstatement: Insured’s second application and deposit were submitted on the day of death but unapproved before death. Policy and Application

Petition for Review on Certiorari under Rule 45 assails:
- RTC Decision dated 30 August 2007 dismissing petitioner’s claim for death benefits.
- RTC Orders of 10 April 2008 and 3 July 2008 declaring the Decision final and denying petitioner’s Notice of Appeal.
Petitioner directly elevated the matter to the Supreme Court via Rule 45 petition, raising procedural and substantive issues.
Insular Life moved to dismiss for lack of timely appeal; Supreme Court treated the petition on both procedural and substantive grounds.

Eulogio C. Lalican took out Policy No. 9011992 on 24 April 1997 with a 20-Year Endowment Variable Income Package Flexi Plan (P500,000) and two riders (P500,000 each), total P1,500,000.
Violeta R. Lalican named primary beneficiary; quarterly premiums of P8,062 due each 24th of April, July, October, January, with a 31-day grace period.
Premiums for July and October 1997 were paid; January 1998 premium went unpaid past grace period, causing automatic lapse on 24 February 1998.
First Application for Reinstatement on 26 May 1998 with P8,062; Insular Life required additional interest (P322.48) and fresh application.
Second Application for Reinstatement on 17 September 1998 with P17,500 to cover overdue interest and subsequent premiums.
Eulogio died later that same day; agent forwarded documents next day, but Insular Life learned of death and took no further action.
Violeta filed a death claim on 28 September 1998; Insular Life denied liability on 14 January 1999, refunded P25,417 representing total premiums and interests paid.
Petitioner’s counsel demanded reconsideration; Insular Life re-evaluated but reaffirmed denial on 10 March 1999; petitioner returned the refund check.
Without awaiting re-evaluation results, petitioner filed Complaint for Death Claim Benefit (Civil Case No. 2177) on 11 October 1999.

Whether the Supreme Court may review the RTC Decision after it became final and exec