Case Summary (G.R. No. 185891)
Complaint Details and Cause of Action
Private respondents filed their complaint on June 20, 1995, claiming that their late father, insured under Life Insurance Policy No. 1305486 with a face value of ₱50,000, passed away from coronary thrombosis on November 25, 1980. They alleged that they continuously made claims for the policy's proceeds since June 22, 1981, but the petitioner denied their claim on February 14, 1995, citing concealment of prior medical conditions by the deceased.
Procedural History and Arguments
Following the filing of the complaint, the petitioner moved to dismiss the case, arguing that the cause of action had prescribed due to the lapse of the ten-year period provided by law, specifically invoking the doctrine of laches. The Regional Trial Court (RTC) initially set the case for trial, asserting that the matters raised were evidentiary and required resolution at that stage.
RTC's Orders and Jurisdiction
On December 12, 1997, the RTC ruled that the ten-year prescriptive period did not begin until February 14, 1995, when the insurer formally rejected the claim. The RTC found that a request for reconsideration on May 25, 1983, effectively interrupted the prescriptive period. The RTC's reliance on the private respondents' counsel's explanations was criticized, as it lacked sufficient evidentiary support.
Court of Appeals Decision
The Court of Appeals upheld the RTC's decision regarding the commencement of the prescriptive period, emphasizing that the cause of action did not accrue until the final rejection by the insurer. However, while it supported the RTC’s initial order, it was criticized for failing to recognize the RTC's grave abuse of discretion in the December 12, 1997 order.
Legal Framework and Interpretation
Applicable law includes provisions of the Civil Code regarding prescription, specifically Article 1144, which states that actions on written contracts must be bro
...continue readingCase Syllabus (G.R. No. 185891)
Case Citation
- G.R. No. 139776
- Date of Decision: August 01, 2002
- Reported in: 435 Phil. 104
Parties Involved
- Petitioner: Philippine American Life and General Insurance Company
- Respondents: Judge Lore R. Valencia-Bagalacsa, Regional Trial Court of Libmanan, Camarines Sur, Branch 56; Eduardo Z. Lumaniog, Celso Z. Lumaniog, and Ruben Z. Lumaniog
Procedural Background
- The petitioner seeks a review on certiorari under Rule 45 of the Rules of Court to reverse the decision of the Court of Appeals dated April 30, 1999.
- The petitioner requests the dismissal of the complaint filed by private respondents in Civil Case No. L-787, on the grounds of prescription of action.
Facts of the Case
- On June 20, 1995, the private respondents filed a complaint against the petitioner for recovery of sums under Life Insurance Policy No. 1305486.
- The policy had a face value of ₱50,000.00, with the insured, Faustino Lumaniog, having died on November 25, 1980.
- Private respondents alleged continuous claim attempts for the proceeds totaling ₱641,000.00 since June 22, 1981, with the last demand on December 1, 1994.
- The petitioner refused the claim on February 14, 1995, citing concealment of health conditions by the insured.
Arguments Presented
- Petitioner’s Position:
- Claimed that the cause of action filed by private respondents had prescribed and they were guilty of laches.
- Denial of the claim communicated through letters dated March 12, 1982, and July 11, 1983, was emphasized.
- Private Respondents’ Position:
- Opposed the moti