G.R. No. 211212 - Sun Life of Canada , Inc. vs. Sibya

The case involves a petition for review on certiorari under Rule 45 of the Rules of Court.
The petitioner, Sun Life of Canada (Philippines), Inc., seeks to annul the Decision and Resolution of the Court of Appeals (CA).
The CA affirmed the Regional Trial Court (RTC) ruling, which ordered Sun Life to pay death benefits and damages to the respondents.
The CA modified the RTC decision by absolving Sun Life from charges of violating the Insurance Code.

Atty. Jesus Sibya, Jr. applied for life insurance with Sun Life on January 10, 2001, disclosing prior kidney treatment.
Sun Life approved the application and issued Insurance Policy No. 031097335 on February 5, 2001, naming the respondents as beneficiaries.
Atty. Jesus Jr. died on May 11, 2001, from a gunshot wound, prompting Ma. Daisy to file a claim for death benefits.
Sun Life denied the claim, citing non-disclosure of Atty. Jesus Jr.'s medical history and subsequently filed a Complaint for Rescission against the respondents.

The RTC dismissed Sun Life's complaint on March 16, 2009, ruling that Sun Life violated the Insurance Code by refusing to pay the claim.
The RTC found no material concealment or misrepresentation by Atty. Jesus Jr. in his insurance application.
The court ordered Sun Life to pay P1,000,000.00 in death benefits, along with moral and exemplary damages, and attorney's fees.

The CA affirmed the RTC's decision on November 18, 2013, ordering Sun Life to pay the death benefits and damages.
The CA modified the RTC's ruling by absolving Sun Life from violations of the Insurance Code, finding no fraudulent intent in Atty. Jesus Jr.'s application.
Sun Life's Motion for Partial Reconsideration was denied on February 13, 2014, leading to the petition for review.

The primary issue is whether the CA erred in affirming the RTC's finding that there was no concealment or misrepresentation in Atty. Jesus Jr.'s insurance application.

The Supreme Court found the petition without merit, referencing the precedent set in Manila Bankers Life Insurance Corporation v. Aban.
The Court emphasized that if the insured dies within the two-year contestability period, the insurer must fulfill its obligations under the policy.
Sun Life's right to rescind the policy was rendered moot by Atty. Jesus Jr.'s death occurring only three months after the policy's issuance.

The Court agreed with the CA's conclusion that Sun Life failed to demonstrate concealment or misrepresentation by Atty. Jesus Jr.
Atty. Jesus Jr. had disclosed his medical history and authorized Sun Life to investigate further.
The Court noted that Atty. Jesus Jr.&#...continue reading