Title
Steel Corp. of the Philippines vs. Mapfre Insular Insurance Corp.
Case
G.R. No. 201199
Decision Date
Oct 16, 2013
SCP, under rehabilitation, claimed insurance from insurers for fire-damaged assets. Courts ruled rehabilitation lacks jurisdiction; SCP must file a separate case for claims.
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Case Summary (G.R. No. 201199)

Case Overview

  • The case involves a petition for review on certiorari filed by Steel Corporation of the Philippines (SCP) against several insurance companies.
  • SCP challenges the Court of Appeals' decision that declared void the Regional Trial Court's (RTC) order directing the insurance companies to pay SCP for insurance claims.
  • The RTC had previously ruled in favor of SCP, allowing it to claim insurance proceeds for damages incurred from fire incidents.

Background Facts

  • SCP is a domestic corporation engaged in manufacturing steel products and had secured loans from various creditors, mortgaging its assets.
  • A Mortgage Trust Indenture (MTI) required SCP to insure its assets, with insurance proceeds payable to the Bank of the Philippine Islands (BPI), the appointed trustee.
  • SCP faced financial difficulties, leading to a corporate rehabilitation petition filed by one of its creditors in 2006, which resulted in a stay order on claims against SCP.

Insurance Claims and RTC Orders

  • SCP had insurance coverage for its assets under a collective master policy and suffered a fire incident in 2008, receiving $450,000 in insurance proceeds, which BPI withheld.
  • In 2009, another fire incident occurred, prompting SCP to file a motion for the insurance proceeds amounting to $28 million for property damage and $8 million for business interruption.
  • The RTC initially ruled in favor of SCP, ordering the insurance companies to pay the claimed amounts.

Court of Appeals' Ruling

  • The Court of Appeals later reversed the RTC's decision, declaring that the RTC lacked jurisdiction over SCP's insurance claims.
  • The appellate court emphasized that rehabilitation courts only have jurisdiction over claims by creditors against the distressed company, not claims by the company against its debtors.

Jurisdictional Issues

  • The Court of Appeals found that SCP's motion for payment of insurance proceeds constituted a collection suit, which should be filed in a separate proceeding.
  • The appellate court highlighted that jurisdiction over a case is acquired upon the payment of prescribed fees, which SCP failed to comply with in its motion.

SCP's Arguments

  • SCP contended that the Court of Appeals erred in entertaining the insurers' petition for certiorari and in ruling that the RTC acted with grave abuse of discretion.
  • SCP argued that the rehabilitation court had jurisdiction to direct the insurers to pay the insurance proceeds necessary for its rehabilitation.

Supreme Court's Ruling

  • The Supreme Court affirmed the Court of Appeals' decision, stating that the RTC did not have jurisdiction over SCP's insurance claims.
  • The Court clarified th...continue reading

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