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Mayer Steel Pipe vs. CA
273 SCRA 432 (1997)



INSURANCE LAW: Contract of Insurance

FACTS:

Hong Kong Government Supplies Department contracted Mayer Steel Pipe
Corporation to manufacture and supply various steel pipes and fittings. Prior to the
shipping, Mayer insured these pipes and fittings against all risks with South Sea
Surety and Insurance Co., Inc. and Charter Insurance Corp., with Industrial
Inspection Inc. appointed as third-party inspector.

After examining the pipes and fittings, Industrial Inspection certified that they are in
good order condition. However, when the goods reached Hong Kong, it was
discovered that a substantial portion thereof was damaged.

The trial court found in favor of the insured. However, when the case was elevated
to the CA, it set aside the decision of the trial court and dismissed the complaint on
the ground of prescription. It held that the action was barred under Sec. 3(6) of the
Carriage of Goods by Sea Act (COGSA) since it was filed only on April 17, 1986,
more than two years from the time the goods were unloaded from the vessel.

ISSUE:


Whether or not the action is barred by prescription

HELD:

Sec. 3(6) of the COGSA states that the carrier and the ship shall be discharged from
all liability for loss or damage to the goods if no suit is filed within one year after
delivery of the goods or the date when they should have been delivered. Under this

provision, only the carrier’s liability is extinguished if no suit is brought within one
year. But the liability of the insurer is not extinguished because the insurer’s liability
is based not on the contract of carriage but on the contract ofinsurance.
An insurance contract is a contract whereby one party, for a consideration known as
the premium, agrees to indemnify another for loss or damage which he may suffer
from a specified peril. An “all risks” insurance policy covers all kinds of loss other
than those due to willful and fraudulent act of the insured. Thus, when private
respondents issued the “all risks” policies to Mayer, they bound themselves to
indemnify the latter in case of loss or damage to the goods insured. Such obligation
prescribes in ten years, in accordance with Article 1144 of the New Civil Code.
Insurance Case Digest: Guingon V. Del Monte, 20 SCRA 1043 (1967)
G.R. No. L-22042
August 17, 1967
Lessons Applicable: Stipulation Pour Autrui (Insurance)

FACTS:

Julio Aguilar owner and operator of several jeepneys insured them


with Capital Insurance & Surety Co., Inc.
February 20, 1961: Along the intersection of Juan Luna and Moro streets, City



of Manila, the jeepneys operated by Aguilar driven by Iluminado del
Monte and Gervacio Guingon bumped and Guingon died some days after
Iluminado del Monte was charged with homicide thru reckless imprudence



and was penalized 4 months imprisonment
The heirs of Gervacio Guingon filed an action for damages praying that



P82,771.80 be paid to them jointly and severally by thedriver del Monte, owner
and operator Aguilar, and the CapitalInsurance & Surety Co., Inc.
CFI: Iluminado del Monte and Julio Aguilar jointly and severally to pay



plaintiffs the sum of P8,572.95 as damages for the death of their father, plus
P1,000.00 for attorney's fees plus costs
Capital Insurance and Surety Co., Inc. is hereby sentenced to
pay P5,000 plus P500 as attorney's fees and costs to be applied in partial

satisfaction of the judgment rendered against Iluminado del Monte and Julio
Aguilar in this case
ISSUE:
1. W/N there a stipulation pour autriu to enable that will enable the heirs to sue
against Capital Insurance and Surety Co., Inc.? - YES
2. W/N the heirs can sue the insurer and insured jointly? - YES

HELD: Affirmed in toto.

1. YES

policy: the insurer agreed to indemnify the insured "against all sums . . .



which the Insured shall become legally liable to pay in respect of: a. death of or
bodily injury to any person . . . ." - indemnity against liability
TEST: Where the contract provides for indemnity against liability to third

persons, then third persons to whom the insured is liable, CAN sue the
insurer. Where the contract is for indemnity against actual loss or payment, then
third persons CANNOT proceed against the insurer, the contract being solely to
reimburse the insured for liability actually discharged by him thru payment to
third persons, said third persons' recourse being thus limited to the insured
alone.
2. YES

policy: expressly disallows suing the insurer as a co-defendant of the insured


in a suit to determine the latter's liability
no action close: suit and final judgment be first obtained against the



insured; that only "thereafter" can the person injured recover on the policy
Sec. 5 of Rule 2 on "Joinder of causes of action" and Sec. 6 of Rule 3 on
"Permissive joinder of parties" cannot be superseded, at least with respect to
third persons not a party to the contract, as herein, by a "no action" clause in
the contract of insurance.

Bonifacio Bros. v. Mora
20 SCRA 262
Facts:
> Enrique Mora mortgaged his Odlsmobile sedan car to HS Reyes Inc. with the condition that
Mora would insure the car with HS Reyes as beneficiary.> The car was then insured with State
Insurance Company and the policy delivered to Mora.

> During the effectivity of the insurance contract, the car figured in an accident. The company
then assigned the accident to an insurance appraiser for investigation and appraisal of the
damage.
> Mora without the knowledge and consent of HS Reyes, authorized Bonifacio Bros to fix the
car, using materials supplied by the Ayala Auto Parts Company.
> For the cost of Labor and materials, Mora was billed P2,102.73. The bill was sent to the
insurer’s appraiser. The insurance company drew a check in the amount of the insurance
proceeds and entrusted the check to its appraiser for delivery to the proper party.
> The car was delivered to Mora without the consent of HS Reyes, and without payment to
Bonifacio Bros and Ayala.
> Upon the theory that the insurance proceeds should be directly paid to them, Bonifacio and
Ayala filed a complaint against Mora and the insurer with the municipal court for the collection of
P2,102.73.
> The insurance company filed its answer with a counterclaim for interpleader, requiring
Bonifacio and HS Reyes to interplead in order to determine who has a better right to the
proceeds.
Issue:
Whether or not there is privity of contract between Bonficacio and Ayala on one hand and State
Insurance on the other.
Held:
NONE.
It is fundamental that contracts take effect only between the parties thereto, except in some
specific instance provided by law where the contract contains some stipulation in favor of a third
person. Such stipulation is known as a stipulation pour autrui; or a provision in favor of a third
person not a party to the contract.

Under this doctrine, a third person is ed to avail himself of a benefit granted to him by the terms
of the contract, provided that the contracting parties have clearly and deliberately conferred a
favor upon such person. Consequently, a third person NOT a party to the contract has NO
action against the aprties thereto, and cannot generally demand the enforcement of the same.

The question of whether a third person has an enforceable interest in a contract must be settled
by determining whether the contracting parties intended to tender him such an interest by
deliberately inserting terms in their agreement with the avowed purpose of conferring favor upon
such third person. IN this connection, this court has laid down the rule that the fairest test to
determine whether the interest of a 3rdperson in a contract is a stipulation pour autrui or merely
an incidental interest, is to rely upon the intention of the parties as disclosed by their contract.

In the instant case the insurance contract does not contain any words or clauses to disclose an
intent to give any benefit to any repairmen or material men in case of repair of the car in
question. The parties to the insurance contract omitted such stipulation, which is a circumstance
that supports the said conclusion. On the other hand, the "loss payable" clause of the insurance
policy stipulates that "Loss, if any, is payable to H.S. Reyes, Inc." indicating that it was only the
H.S. Reyes, Inc. which they intended to benefit.

A policy of insurance is a distinct and independent contract between the insured and insurer,
and third persons have no right either in a court of equity, or in a court of law, to the proceeds of
it, unless there be some contract of trust, expressed or implied, by the insured and third person.
In this case, no contract of trust, express or implied. In this case, no contract of trust, expressed
or implied exists. We, therefore, agree with the trial court that no cause of action exists in favor
of the appellants in so far as the proceeds of insurance are concerned. The appellant's claim, if
at all, is merely equitable in nature and must be made effective through Enrique Mora who
entered into a contract with the Bonifacio Bros Inc. This conclusion is deducible not only from
the principle governing the operation and effect of insurance contracts in general, but is clearly
covered by the express provisions of section 50 of the Insurance Act (now Sec. 53).

The policy in question has been so framed that "Loss, if any, is payable to H. S. Reyes, Inc."
which unmistakably shows the intention of the parties.

FINMAN GENERAL ASSURANCE CORPORATION vs. THE HONORABLE COURT OF
APPEALS
FINMAN GENERAL ASSURANCE CORPORATION vs. THE HONORABLE COURT OF
APPEALS 213 SCRA 493, September 2, 1992 NOCON, J.:

FACTS:
On October 22, 1986, deceased, Carlie Surposa was insured with petitioner Finman General
Assurance Corporation with his parents, spouses Julia and Carlos Surposa, and brothers
Christopher, Charles, Chester and Clifton, all surnamed, Surposa, as beneficiaries. While said
insurance policy was in full force and effect, the insured, Carlie Surposa, died on October 18,
1988 as a result of a stab wound inflicted by one of the three (3) unidentified men. Private
respondent and the other beneficiaries of said insurance policy filed a written notice of claim
with the petitioner insurance company which denied said claim contending that murder and
assault are not within the scope of the coverage of the insurance policy. Private respondent filed
a complaint with the Insurance Commission which rendered a favorable response for the
respondent. The appellate court ruled likewise. Petitioner filed this petition alleging grave abuse
of discretion on the part of the appellate court in applying the principle of "expresso unius
exclusio alterius" in a personal accident insurance policy, since death resulting from murder
and/or assault are impliedly excluded in said insurance policy considering that the cause of
death of the insured was not accidental but rather a deliberate and intentional act of the
assailant. Therefore, said death was committed with deliberate intent which, by the very nature
of a personal accident insurance policy, cannot be indemnified.

ISSUE: Whether or not the insurer is liable for the payment of the insurance premiums

HELD:

Yes, the insurer is still liable. Contracts of insurance are to be construed liberally in favor of the
insured and strictly against the insurer. Thus ambiguity in the words of an insurance contract
should be interpreted in favor of its beneficiary. The terms "accident" and "accidental" as used in
insurance contracts have not acquired any technical meaning, and are construed by the courts in
their ordinary and common acceptation. Thus, the terms have been taken to mean that which
happen by chance or fortuitously, without intention and design, and which is unexpected,
unusual, and unforeseen. Where the death or injury is not the natural or probable result of the
insured's voluntary act, or if something unforeseen occurs in the doing of the act which produces
the injury, the resulting death is within the protection of the policies insuring against death or
injury from accident. In the case at bar, it cannot be pretended that Carlie Surposa died in the
course of an assault or murder as a result of his voluntary act considering the very nature of
these crimes. Neither can it be said that where was a capricious desire on the part of the accused
to expose his life to danger considering that he was just going home after attending a festival.
Furthermore, the personal accident insurance policy involved herein specifically enumerated
only ten (10) circumstances wherein no liability attaches to petitioner insurance company for
any injury, disability or loss suffered by the insured as a result of any of the stimulated causes.
The principle of " expresso unius exclusio alterius" — the mention of one thing implies the
exclusion of another thing — is therefore applicable in the instant case since murder and assault,
not having been expressly included in the enumeration of the circumstances that would negate
liability in said insurance policy cannot be considered by implication to discharge the petitioner
insurance company from liability for, any injury, disability or loss suffered by the insured. Thus,
the failure of the petitioner insurance company to include death resulting from murder or
assault among the prohibited risks leads inevitably to the conclusion that it did not intend to
limit or exempt itself from liability for such death.
Sun v CA G.R. No. 89741 March 13, 1991
J. Paras
Facts:
Tan took from Sun Insurance a Php 300,000 policy to cover his electrical store in Iloilo city. Tan’s
request for an indemnity in 1983 was repeatedly denied, firstly in 1984. He wrote for a
reconsideration in the same year. This was rejected in 1985, prompting him to file a civil case in
the same year. The insurance company filed a motion to dismiss due to prescription in 1987,
but this was denied. The company went to the court of appeals to petition the same thing, but
this was denied.

Issue:
1. WON the filing of a motion for reconsideration interrupts the twelve months prescriptive
period to contest the denial ofthe insurance claim.

2. WON the rejection of the claim shall be deemed final only if it contains words to the effect that
denial is final. (ie. the first letter in 1984)
3. When does the cause of action accrue?
Held:
1.No
2.No
3. At the time of the first rejection of the insurance company
Ratio:
1. The policy states in section 27.
Action or suit clause — If a claim be made and rejected and an action or suit be not commenced
either in the InsuranceCommission or in any court of competent jurisdiction within twelve (12)
months from receipt of notice of such rejection, or in case of arbitration taking place as provided
herein, within twelve (12) months after due notice of the award made by the arbitrator or
arbitrators or umpire, then the claim shall for all purposes be deemed to have been abandoned
and shall not thereafter be recoverable hereunder.
Respondent Tan admitted that he received a copy of the letter of rejection on April 2, 1984.
Thus, the 12-month prescriptive period started to run from the said date of April 2, 1984, under
section 27.
2. It was clear in the letter.
Ang v. Fulton Fire Insurance Co.- The condition contained in an insurance policy that claims
must be presented within one year after rejection is not merely a procedural requirement but an
important matter essential to a prompt settlement of claims against insurance companies as it
demands that insurance suits be brought by the insured while the evidence as to the origin and
cause of destruction have not yet disappeared.
Therefore, there was a necessity of bringing suits against the Insurer within one year from the
rejection of the claim. (1984) The contention of the respondents that the one-year prescriptive
period does not start to run until the petition for reconsideration had been resolved by the
insurer (1985), runs counter to the doctrine.
The provision in the contract was pursuant to Sec. 63.
A condition, stipulation or agreement in any policy of insurance, limiting the time for
commencing an action thereunder to a period of less than one year from the time when the
cause of action accrues, is void.

3. Eagle star- The right of the insured to the payment of his loss accrues from the happening of
the loss. However, the cause of action in an insurance contract does not accrue until the
insured's claim is finally rejected by the insurer. This is because before such final rejection there
is no real necessity for bringing suit.
The cause of action, then, started when the insurer denied his claim in the first instance(1984).
This rejection of a petition for reconsideration as insisted by respondents wasn’t the beginning
of the cause of action.

Insurance Case Digest: Gallardo V. Morales (1960)
G.R. No. L-12189 April 29, 1960
Lessons Applicable: Definition and Coverage of Life Insurance (Insurance)
Laws Applicable: Rule 39, section 12, subdivision (k) of the Rules of Court (old law)

FACTS:



CFI: Hermenegilda S. Morales to pay P7,000 to a creditor Francisca Gallardo
writ of execution was issued and delivered to the Sheriff who garnished and



levied execution on the sum of P7,000 out of the P30,000 due from the
Capital Insurance & Surety Co. Inc., to Morales as beneficiary whose
husband Luis Morales died by assassination.
Morales asked the sheriff to quash and lift said garnishment or levy on



execution invoking Rule 39, section 12, subdivision (k) of the Rules of Court but
it was denied.
All moneys, benefits, privileges, or annuities accruing or in any manner



growing out of any life insurance, if the annual premiums paid do not exceed
five hundred pesos, and if they exceed that sum a like exemption shall exist
which shall bear the same proportion to the moneys, benefits, privileges, and
annuities so accruing or growing out of such insurance that said five hundred
pesos bears to the whole annual premiums paid.
Morales appealed maintaining that it was a life insurance for it insured her

husband for injuries and/or death as a result of murder or assault or attempt
thereat
ISSUE: W/N the insurance is a life insurance and not an accident insurance

HELD: NO. order appealed from is reversed, and the garnishment in dispute hereby
set aside and quashed



the annual premium was for P15
If it were an ordinary life insurance policy, taking into account that the



insured, Luis G. Morales, was 38 years of age and the amount of the policy was
for P50,000.00 the annual premium would have been around P1,206
the period for the policy was stipulated for one year, and considerations as to



age, health, occupation and other personal circumstances were not taken into
account in an accident insurancepolicy
Annex "1" of the opposition, shows that the Capital Insurance and Surety







Company Inc. is a non-life insurance company and that the only authority
granted to it to transact business covers fire, marine, surety, fidelity, accident,
motor car, and miscellaneous insurance, except life insurance
Accident vs Life Insurance Policy
accident policy - merely insures the person from injury and or death
resulting from murder, assault, or an attempt thereat
Accident insurance
indemnity or casualty contract
life insurance policy - what is insured is the life of the subject for a



definite number of years
life insurance
investment contract
contract by which the insurer, for a stipulated sum,



engages to pay a certain amount of money if another dies within the time
limited by the policy
contract for insurance for one year in consideration of an



advanced premium, with the right of assured to continue it from year to year
upon payment of a premium as stipulated
includes accident insurance, since life is insured under




either contract


includes all policies of insurance in



which payment of insurance money is contingent upon loss of life
"any life insurance"
applies to ordinary life insurance contracts, as well as to those which,



although intended primarily to indemnify for risks arising from accident, likewise,
insure against loss of life due, either to accidental causes, or to the willful and
criminal act of another, which, as such, is not strictly accidental in nature



statutes of this nature seek to enable the head of the family to secure
his widow and children from becoming a burden upon the community and,
accordingly, should merit a liberal interpretation

Insurance Case Digest: De La Cruz V. Capital Ins. & Surety Co, Inc. (1966)
G.R. No. L-21574

June 30, 1966

Lessons Applicable: Liability of Insurer for Suicide and Accidental Death (Insurance)
Laws Applicable:

FACTS:


Eduardo de la Cruz, employed as a mucker in the Itogon-Suyoc Mines, Inc. in
Baguio, was the holder of an accident insurancepolicy "against death or



disability caused by accidental means"
January 1, 1957: For the celebration of the New Year, the Itogon-Suyoc Mines,



Inc. sponsored a boxing contest for general entertainment wherein Eduardo, a
non-professional boxer participated
In the course of his bout with another non-professional boxer of the same



height, weight, and size, Eduardo slipped and was hit by his opponent on the left
part of the back of the head, causing Eduardo to fall, with his head hitting the
rope of the ring
He was brought to the Baguio General Hospital the following day. He died



due to hemorrhage, intracranial.
Simon de la Cruz, the father of the insured and who was named beneficiary



under the policy, thereupon filed a claim with the insurance company
The Capital Insurance and Surety co., inc denied stating that the death



caused by his participation in a boxing contest was not accidental
RTC: favored Simon

ISSUE: W/N the cause of death was accident

HELD:YES.




Eduardo slipped, which was unintentional
The terms "accident" and "accidental"
as used in insurance contracts, have not acquired any technical
meaning and are construed by the courts in their ordinary and common



acceptation
happen by chance or fortuitously, without intention and design, and
which is unexpected, unusual, and unforeseen



event that takes place without one's foresight or expectation
event that proceeds from an unknown cause, or is an unusual effect of



a known cause and, therefore, not expected
where the death or injury is not the natural or probable result of the insured's



voluntary act, or if something unforeseen occurs in the doing of the act which
produces the injury, the resulting death is within the protection of policies
insuring against death or injury from accident
while the participation of the insured in the boxing contest is voluntary, the



injury was sustained when he slid, giving occasion to the infliction by his
opponent of the blow that threw him to the ropes of the ring is not
The fact that boxing is attended with some risks of external injuries does not



make any injuries received in the course of the game not accidental
In boxing as in other equally physically rigorous sports, such as basketball or



baseball, death is not ordinarily anticipated to result. If, therefore, it ever does,
the injury or death can only be accidental or produced by some unforeseen
happening or event as what occurred in this case
Furthermore, the policy involved herein specifically excluded from its



coverage —
(e) Death or disablement consequent upon the Insured engaging in football,
hunting, pigsticking, steeplechasing, polo-playing, racing of any kind,
mountaineering, or motorcycling.
Death or disablement resulting from engagement in boxing contests



was not declared outside of the protection of the insurance contract

Insurance Case Digest: Guingon V. Del Monte, 20 SCRA 1043 (1967)
G.R. No. L-22042

August 17, 1967

Lessons Applicable: Stipulation Pour Autrui (Insurance)

FACTS:


Julio Aguilar owner and operator of several jeepneys insured them
with Capital Insurance & Surety Co., Inc.



February 20, 1961: Along the intersection of Juan Luna and Moro streets, City



of Manila, the jeepneys operated by Aguilar driven by Iluminado del
Monte and Gervacio Guingon bumped and Guingon died some days after
Iluminado del Monte was charged with homicide thru reckless imprudence



and was penalized 4 months imprisonment
The heirs of Gervacio Guingon filed an action for damages praying that



P82,771.80 be paid to them jointly and severally by the driver del Monte, owner
and operator Aguilar, and the Capital Insurance & Surety Co., Inc.
CFI: Iluminado del Monte and Julio Aguilar jointly and severally to pay



plaintiffs the sum of P8,572.95 as damages for the death of their father, plus
P1,000.00 for attorney's fees plus costs
Capital Insurance and Surety Co., Inc. is hereby sentenced to
pay P5,000 plus P500 as attorney's fees and costs to be applied in partial

satisfaction of the judgment rendered against Iluminado del Monte and Julio
Aguilar in this case
ISSUE:
1. W/N there a stipulation pour autriu to enable that will enable the heirs to sue
against Capital Insurance and Surety Co., Inc.? - YES
2. W/N the heirs can sue the insurer and insured jointly? - YES

HELD: Affirmed in toto.

1. YES




policy: the insurer agreed to indemnify the insured "against all sums . . .
which the Insured shall become legally liable to pay in respect of: a. death of or
bodily injury to any person . . . ." - indemnity against liability
TEST: Where the contract provides for indemnity against liability to third
persons, then third persons to whom the insured is liable, CAN sue the
insurer. Where the contract is for indemnity against actual loss or payment, then
third persons CANNOT proceed against the insurer, the contract being solely to
reimburse the insured for liability actually discharged by him thru payment to
third persons, said third persons' recourse being thus limited to the insured
alone.

2. YES


policy: expressly disallows suing the insurer as a co-defendant of the insured



in a suit to determine the latter's liability
no action close: suit and final judgment be first obtained against the



insured; that only "thereafter" can the person injured recover on the policy
Sec. 5 of Rule 2 on "Joinder of causes of action" and Sec. 6 of Rule 3 on
"Permissive joinder of parties" cannot be superseded, at least with respect to
third persons not a party to the contract, as herein, by a "no action" clause in
the contract of insurance.



Insurance Case Digest: Guingon V. Del Monte, 20 SCRA 1043 (1967)
G.R. No. L-22042

August 17, 1967

Lessons Applicable: Stipulation Pour Autrui (Insurance)

FACTS:


Julio Aguilar owner and operator of several jeepneys insured them



with Capital Insurance & Surety Co., Inc.
February 20, 1961: Along the intersection of Juan Luna and Moro streets, City



of Manila, the jeepneys operated by Aguilar driven by Iluminado del
Monte and Gervacio Guingon bumped and Guingon died some days after
Iluminado del Monte was charged with homicide thru reckless imprudence



and was penalized 4 months imprisonment
The heirs of Gervacio Guingon filed an action for damages praying that



P82,771.80 be paid to them jointly and severally by the driver del Monte, owner
and operator Aguilar, and the Capital Insurance & Surety Co., Inc.
CFI: Iluminado del Monte and Julio Aguilar jointly and severally to pay



plaintiffs the sum of P8,572.95 as damages for the death of their father, plus
P1,000.00 for attorney's fees plus costs
Capital Insurance and Surety Co., Inc. is hereby sentenced to
pay P5,000 plus P500 as attorney's fees and costs to be applied in partial
satisfaction of the judgment rendered against Iluminado del Monte and Julio
Aguilar in this case

ISSUE:
1. W/N there a stipulation pour autriu to enable that will enable the heirs to sue
against Capital Insurance and Surety Co., Inc.? - YES
2. W/N the heirs can sue the insurer and insured jointly? - YES

HELD: Affirmed in toto.

1. YES




policy: the insurer agreed to indemnify the insured "against all sums . . .
which the Insured shall become legally liable to pay in respect of: a. death of or
bodily injury to any person . . . ." - indemnity against liability
TEST: Where the contract provides for indemnity against liability to third

persons, then third persons to whom the insured is liable, CAN sue the
insurer. Where the contract is for indemnity against actual loss or payment, then
third persons CANNOT proceed against the insurer, the contract being solely to
reimburse the insured for liability actually discharged by him thru payment to
third persons, said third persons' recourse being thus limited to the insured
alone.
2. YES


policy: expressly disallows suing the insurer as a co-defendant of the insured



in a suit to determine the latter's liability
no action close: suit and final judgment be first obtained against the



insured; that only "thereafter" can the person injured recover on the policy
Sec. 5 of Rule 2 on "Joinder of causes of action" and Sec. 6 of Rule 3 on
"Permissive joinder of parties" cannot be superseded, at least with respect to
third persons not a party to the contract, as herein, by a "no action" clause in
the contract of insurance.

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