Case Summary (G.R. No. 100599)
Applicable Law
The relevant law in this case is governed under the Civil Code of the Philippines, specifically concerning insurance contracts and obligations between insurers and insured parties.
Facts of the Case
The dispute revolves around Fire Insurance Policy No. 9652, which was issued on April 1, 1960, by Philippine Phoenix Surety & Insurance, Inc., for a coverage amount of P300,000. The total premiums owed amounted to P6,051.95, which included a margin fee and documentary stamps. Woodworks, Inc. made a partial payment of P3,000.00 on September 22, 1960, but failed to pay the remaining balance of P3,522.09 despite several demands for payment from the plaintiff.
Court Proceedings
Following the municipal court's judgment against Woodworks, the defendant appealed the case to the Court of First Instance of Manila. The parties submitted a stipulation of facts detailing the issuance of the insurance policy, payments made, and the outstanding balance due.
Legal Issues Raised in Appeal
Woodworks, Inc. raised several points of error in its appeal:
- The lower court's assertion that risk is attached to the issuance and delivery of the policy to the insured.
- The conclusion that a perfected contract of insurance is not canceled by non-payment of premiums.
- The determination that the premium was still collectible when the complaint was filed.
- The assertion that the partial payment made the policy effective for the entire duration even with the remaining balance.
Rulings on Legal Issues
The Supreme Court found that there was a perfected, albeit partially performed, contract of insurance upon issuance and partial payment of the premium. Therefore, the insurer had rights to demand the balance of the premium, and the non-payment did not automatically cancel the insurance contract. The Court rejected the appellant's argument that it had unilateral discretion to invalidate the contract due to u
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Case Overview
- This case involves an appeal by Woodworks, Inc. against the judgment of the Court of First Instance of Manila regarding a fire insurance policy.
- The judgment ordered Woodworks, Inc. to pay Philippine Phoenix Surety & Insurance, Inc. the sum of P3,522.09, with interest and costs.
- The appeal addresses several alleged errors committed by the lower court in its findings related to the insurance contract and the payment of premiums.
Parties Involved
- Plaintiff-Appellee: Philippine Phoenix Surety & Insurance, Inc.
- Defendant-Appellant: Woodworks, Inc.
- Both parties are corporations duly organized under Philippine law.
Factual Background
- A fire insurance policy (No. 9652) was issued by the plaintiff to the defendant on April 1, 1960, for an amount of P300,000.00.
- The total premium for the policy was P6,051.95, which included additional fees and documentary stamps.
- Woodworks, Inc. made a partial payment of P3,000.00 on September 22, 1960, leaving an unpaid balance of P3,522.09.
- The plaintiff made several demands for the payment of the outstanding balance.
Legal Issues Presented
- Woodworks, I