Case Summary (G.R. No. 170598)
Facts of the Case
Gloria Dee Chong, the owner of a Fuso truck insured under Commercial Vehicle Policy No. 279675 with Stronghold Insurance Company, filed a claim for P550,000.00 after her vehicle was involved in a fatal accident in Brgy. Palihan, Hermosa, Bataan, resulting in multiple casualties and injuries. The insurance company denied the claim, asserting that the driver was heavily intoxicated at the time of the incident, based on statements from local officials and a medico-legal certificate.
Procedural History
Respondents initiated litigation in the Regional Trial Court (RTC) of Caloocan City after their claim was unjustly denied. The respondents contended there was insufficient evidence of intoxication and insisted on the insurance company’s liability under the policy. The RTC ruled in favor of the respondents, ordering the payment of the insurance claim, while the petitioner appealed the RTC's decision to the Court of Appeals.
Court of Appeals Decision
The Court of Appeals affirmed the RTC's decision, holding that the petitioner failed to provide sufficient evidence to show the driver’s intoxication, thereby necessitating payment of the insurance claim. The appellate court rejected the petitioner's evidence as hearsay and reiterated the absence of intoxication in the police blotter as a critical factor.
Legal Issues Raised by the Petitioner
In its petition, the petitioner raised several issues, arguing that the appellate court erred in not appreciating the evidence of the driver’s intoxication, in finding the petitioner liable, and in upholding the imposition of interest on the awarded claim.
Court's Ruling
The Supreme Court reiterated that it typically does not re-evaluate factual findings. It underscored that the petitioner did not substantiate its claim regarding the driver’s intoxication with credible evidence, emphasizing the dubious nature of the medical certificate. It also mentioned the insufficiency of the evidence presented by the petitioner to counteract the respondents' prima facie case.
Burden of Proof
The Court reinforced the principle that the burden of proving intoxication rested on the petitioner, noting that respondents established enti
...continue readingCase Syllabus (G.R. No. 170598)
Introduction
- This syllabus outlines the case of Stronghold Insurance Company, Incorporated versus Interpacific Container Services and Gloria Dee Chong, focusing on the legal dispute regarding the insurance claim following a vehicular accident.
- The case was decided by the First Division of the Supreme Court of the Philippines, under G.R. No. 194328, on July 1, 2015.
Background of the Case
- Respondent Gloria Dee Chong owned a Fuso truck, insured under Commercial Vehicle Policy No. 279675 by Stronghold Insurance Company.
- The insurance policy provided comprehensive coverage against loss or damage and third-party liabilities for a premium of P15,306.45.
- An accident occurred on the National Highway in Brgy. Palihan, Hermosa, Bataan, resulting in four fatalities and serious injuries to three individuals, along with damage to two vehicles.
Claim for Insurance Proceeds
- Following the accident, respondent Chong filed a claim amounting to P550,000.00, which included:
- Comprehensive Third Party Liability (CTPL): P50,000.00
- Own Damage (OD): P300,000.00
- Excess / Bodily Injury (BI): P100,000.00
- Third Party Liability (TPL): P100,000.00
- The insurance claim was denied by Stronghold Insurance Company, citing the driver's intoxication as the reason for avoidance of the policy.
Legal Proceedings Initiated
- Respondents initiated a legal action in the Regional Trial Court (RTC) of Caloocan City, arguing the denial was unjustified and lack