Case Summary (G.R. No. 103883)
Insurance Policy Details
Marcelino Gabriel was covered by a personal accident insurance policy amounting to PHP 100,000. The policy specified that it would cover death or disability caused solely and directly by “bodily injury caused by violent accidental external and visible means.” The policy came into effect during Gabriel’s employment and remained valid until his death.
Incident and Subsequent Reporting
Gabriel died in Iraq under circumstances that remained unclear, subsequently leading to confusion regarding the insurance claim. A death certificate from the Iraqi Ministry of Health noted that the cause of death was “not yet known,” and the National Bureau of Investigation (NBI) conducted an autopsy that found the cause of death indeterminate due to advanced decomposition. ECDC communicated Gabriel's death to Fortune Insurance on July 12, 1983, over a year after the incident.
Claim Denial and Legal Proceedings
Fortune Insurance rejected the claim for the insurance benefit, citing the reason of prescription under Section 384 of the Insurance Code, which necessitates written notice of the claim within six months of the accident. Following this denial, Jacqueline Jimenez filed a complaint against both Fortune Insurance and ECDC in the Regional Trial Court, asserting that her husband died in an accident while performing his work duties and seeking the insurance benefit along with additional damages.
Trial Court Decision
The Regional Trial Court ruled in favor of the petitioner, determining that Fortune Insurance had waived its defense concerning the cause of death by failing to present counter-evidence disproving the claim. The court also affirmed that the complaint was filed within the one-year limitation following the denial of the claim.
Appeal to the Court of Appeals
Both Jacqueline Jimenez and Fortune Insurance appealed the trial court's decision. The petitioner sought a broader ruling awarding her all claimed damages, whereas Fortune Insurance argued that the trial court had incorrectly dismissed their case regarding the nature of Gabriel's death and the prescription defense.
Court of Appeals Ruling
The Court of Appeals overturned the trial court’s decision, stating that Jacqueline Jimenez failed to provide sufficient evidence that her husband’s death was due to a risk covered by the policy. The appellate court found the evidence—predominantly her own affidavit and a letter from a supposed co-worker—to be hearsay and lacking substantial value.
Legal Principles Involved
The Court underscored that under the Insurance Code, particularly Section 384, a claimant must submit a written notice within six months of the accident or risk waiver of the claim. Furthermore, it highlighted the burden of proof in insurance claims, establishing that the beneficiary must first demonstr
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Case Overview
- This case involves a petition for review on certiorari seeking to reverse the Court of Appeals' decision that overturned the Regional Trial Court (RTC) of Manila's ruling in favor of the petitioner, Jacqueline Jimenez Vda. de Gabriel.
- The RTC had ordered Fortune Insurance & Surety Company, Inc. to pay the petitioner P100,000.00 plus legal interest, as the beneficiary of an accident insurance policy for her deceased husband, Marcelino Gabriel.
Background of the Case
- Marcelino Gabriel was employed by Emerald Construction & Development Corporation (ECDC) and was covered by a personal accident insurance policy for overseas workers, specifically for risks associated with bodily injury caused by violent, accidental, external, and visible means.
- Gabriel died on May 22, 1982, while in Iraq, within the policy's coverage period.
- A year later, ECDC reported Gabriel's death to Fortune Insurance, accompanied by a death certificate stating the cause of death as “under examination” and an NBI autopsy report indicating that the cause of death could not be determined due to advanced decomposition.
Claims and Defenses
- Petitioner claimed her husband died from electrocution while working and sought recovery of the insurance amount along with damages and attorney's fees.
- Fortune Insurance admitted the genuineness of the policy but denied liability, citing the lack of a specified cause of death and invoking the defense of prescription under Section 384 of the Insurance Code.