Case Summary (G.R. No. 176898)
Factual Background
Andres Trinidad applied for membership in the Orient Protective Assurance Association on February 18, 1935, and was issued a life benefit certificate. His membership required payment of an entrance fee and contributions upon the death of a member, with a specified payout scale based on the timing of the death. Andres Trinidad died on January 3, 1936. Following his death, Tarcila notified the association, which sent the necessary forms to file a claim. The association later informed Tarcila that the benefit certificate had been forfeited due to Andres' failure to pay the premium on time.
Procedural History
Tarcila was permitted by the Court of First Instance of Manila to pursue her action as a pauper. She filed a complaint on February 26, 1936, seeking the recovery of P 500 plus legal interest. The defendant responded with a general and specific denial. Following a trial, the lower court ruled in favor of Tarcila on September 26, 1936. The defendant's subsequent motion for a new trial was denied, and although the case was appealed, the lower court granted Tarcila's motion for immediate execution of its judgment on January 21, 1937.
Legal Issues
The primary legal question centers on whether Tarcila has the right to recover the insurance proceeds given the appellant's claim of forfeiture due to the late payment of premiums and the claimed cause of death exempting liability. The association contended that the premium call had been issued timely, and Andres had until December 31, 1935, to pay. However, Tarcila's testimony indicated that a payment of P 2 was made on January 2, 1936, after a delay caused by Andres's serious illness. The payment was accepted by the association without return.
Court's Analysis
The court noted that the acceptance of the late premium payment constitutes a waiver of the right to enforce automatic forfeiture against the beneficiary. Relevant case law supports the principle that conditions leading to forfeiture should be construed in favor of the policyholder and adversely for the insurer.
...continue readingCase Syllabus (G.R. No. 176898)
Case Overview
- This case involves Tarcila L. Trinidad as the plaintiff-appellee and Orient Protective Assurance Association as the defendant-appellant.
- The case was decided on April 5, 1939, and is reported in 67 Phil. 181.
- The case addresses the issues surrounding life insurance benefits and the implications of premium payments and forfeiture.
Parties Involved
- Plaintiff-Appellee: Tarcila L. Trinidad, widow of Andres Trinidad.
- Defendant-Appellant: Orient Protective Assurance Association, a mutual benefit society incorporated under Philippine law.
Background of the Case
- The defendant operates on a mutual or assessment plan, requiring members to pay an entrance fee and contributions for benefits related to death or disability.
- Andres Trinidad applied for membership on February 18, 1935, and received a life benefit certificate.
- He died on January 3, 1936, prompting Tarcila to file a claim for the insurance benefit.
Claims and Correspondence
- After Andres's death, Tarcila notified the defendant and submitted the necessary claim forms.
- The defendant informed her that the benefit certificate was forfeited due to Andres's failure to pay the premium on time.
Legal Proceedings
- Tarcila was permitted by the Court of First Ins