Case Summary (G.R. No. 239989)
Relevant Facts
Pioneer Insurance issued Fire Insurance Policy No. FI-PP-03-0000356-00-D to Unilab, covering its pharmaceutical stock, which was housed in a warehouse owned by Tan. On August 28, 2004, a fire devastated the warehouse, leading Unilab to file a claim under the insurance policy. Unilab subsequently received payment of approximately P13,430,528.22 from Pioneer Insurance, which led the petitioner to seek reimbursement from Tan due to her alleged negligence that contributed to the loss.
Initial Court Findings
The Regional Trial Court (RTC) dismissed Tan's defenses and upheld the insurer's subrogation rights to recover damages. The RTC ruled that regardless of whether the fire was caused by a fortuitous event, Tan still bore financial responsibility due to her obligations under the terms governing the sale of the goods. The court confirmed that the insurance policy remained effective despite the transfer of possession, since Unilab retained insurable interest over the goods until full payment was made.
Appeal and Subsequent Rulings
Upon appeal, the Court of Appeals (CA) affirmed the RTC ruling but modified certain aspects, particularly addressing the legal rate of interest. However, upon further reconsideration, the CA reversed its previous decision, accepting Tan’s argument that the contract with Unilab should be classified as one of consignment rather than a straightforward sale. The CA concluded that Tan, as an agent in a consignment arrangement, could not be held liable to an insurer for the loss of goods.
Supreme Court's Jurisdiction Issues
In its ruling, the Supreme Court clarified the issues surrounding the shift in defense theory by Tan during the appeal process. The Court determined that Tan's change in legal strategy—arguing for a consignment contract—was impermissible as it had not been raised during the initial proceedings. The principle forbidding the introduction of new theories on appeal aligns with fair trial rights, as parties should not be taken by surprise by new arguments introduced at advanced stages of litigation.
Ruling on Subrogation Rights
The Supreme Court reaffirmed Pioneer Insurance’s right to subrogation and its ability to recover amounts paid to Unilab. It highlighted that the obligation of the respondent persisted despite the fire being an unforeseen event. The Court emphasized that based on the terms of the sale, the risk of loss fell on Tan upon delivery, reinforcing the insurer’s position to recover payments made under the policy.
Final Decision
Ultimately, the Supreme Cou
...continue readingCase Syllabus (G.R. No. 239989)
Case Citation
- G.R. No. 239989
- Date of Decision: July 13, 2020
- Court: Supreme Court of the Philippines
Parties Involved
- Petitioner: Pioneer Insurance & Surety Corporation
- Respondent: Carmen G. Tan (also known as Carmen S.F. Gatmaytan) and/or Unknown Owner/Proprietor of Save More Drug
Procedural History
- The case originated from a Petition for Review on Certiorari assailing the Amended Decision dated June 16, 2017, and Resolution dated June 5, 2018, of the Court of Appeals (CA) in CA-G.R. CV No. 103363.
- The CA dismissed the complaint for damages filed by the petitioner against the respondent.
Relevant Antecedents
- Pioneer Insurance & Surety Corporation issued a Fire Insurance Policy to United Laboratories, Inc. (Unilab) covering stocks of various drugs and pharmaceutical products from December 29, 2003, to December 29, 2004.
- The goods were delivered to Carmen G. Tan, owner of Save More Drug, and stored in a warehouse in Quezon City.
- A clause in the Delivery Receipts indicated that while Unilab retained ownership until full payment, the risk of loss passed to the buyer upon delivery.
- On August 28, 2004, a fire destroyed the warehouse, resulting in Unilab filing a claim with the petitioner, which led to the payment of ₱13,430,528.22 for the lost goods.
- The petitioner sought recovery from the respondent, asserting negligence on her part for the loss of goods.
Key Allegations and Arguments
- Petitioner’s Claim:
- The petitioner claimed that Unilab’s delivery of goods to the respondent created a liability for the respondent to reimburse the petitioner due to negligence leading to the loss.
- Respondent’s Defense:
- Carmen G.