Doctrine: Insurers must not be allowed to delay the payment of claims by filing frivolous cases in court, hoping that the inevitable may be put off for years—or even decades—by the pendency of these unnecessary court cases
Facts
Romeo obtained an accident insurance policy from several insurance companies including Philam Life Insurance. One day, as he was coming out of the bathroom, Romeo tripped causing his right eye to hit the arm rest of a chair. He called out to his spouse, Luisa, who promptly rushed to his side
Romeo was immediately brought to the clinic Dr. Villanueva. After a series of check-ups, he underwent an enucleation, a surgical procedure involving the removal of his right eye. On account of the surgery, he incurred medical expenses in the sum of PHP 31,060.00.
Consequently, Romeo filed written notices of injury with the insurance companies. To his dismay, his claims were disapproved based on the joint affidavit of their former household helpers who denied the occurrence of the accident. The disapproval of the claims prompted Romeo and Luisa (spouses Soriano) to lodge separate complaints before the RTC against the insurance companies for accident insurance proceeds, specific performance, damages, and attorney’s fees.
During the trial, spouses Soriano presented themselves and Dr. Villanueva as witnesses. On the other hand, Philam Life proffered the testimony of the househelperand the medical opinion of Dr. Dr. Valenton, a credited physician of Philam Life. In due course, the RTC rendered its Judgment, dismissing the complaints based on the equipoise rule.
Issue
Whether or not the RTC erred in not granting Romeo the insurance proceeds?
Ruling
Yes. In civil cases, the quantum of evidence to be observed is preponderance of evidence. Preponderance of evidence means that the evidence adduced by one side is superior to or has greater weight than that of the other. It means that evidence which is more convincing to the Court as worthy of belief than that which is offered in opposition thereto.
Jurisprudence teaches that when the evidence of the parties are evenly balanced or when there is doubt on which side the evidence preponderates, the decision should be against the party with the burden of proof, according to the equipoise doctrine. Here, the RTC erred in applying the equipoise rule considering that the spouses Soriano were able to prove through preponderance of evidence that Romeo’s injury was caused by an accident, thus entitling him to the proceeds of the subject accident insurance policies.
Their testimonies were sufficiently corroborated by the testimony of Dr. Villanueva, who clearly explained the findings he gathered in his examination of Romeo on January 29, 2001 or the day of the accident
Determined to prove that Romeo was not entitled to the insurance benefits, PhilamLife raised Dr. Valenton ‘s medical opinion to controvert Dr. Villanueva’s testimony. It claims that Dr. Villanueva found no abrasion or hematoma. However, a perusal of Dr. Villanueva’s testimony plainly reveals that he “observed sub-conjunctival harmorhage, hemorrhage occuring in between the consubjunctival sclera of the eye. In contrast, Dr. Valenton, by his own admission, did not personally examine Romeo, but merely offered a different interpretation based on the findings made by Dr. Villanueva
Hence, the Court ordered Philam Life, along with the other insurance companies, to pay jointly and severally actual damages or medical reimbursement to spouses Soriano in the amount of PHP 31,060.00 and the insurance proceeds for the permanent and irrecoverable loss of sight and of Romeo’s right eye.
In so ruling, the Court commiserated with the two-decade plight of spouses Soriano, surpassing the death of Romeo. Certainly, insurers must not be allowed to delay the payment of claims by filing frivolous cases in court, hoping that the inevitable may be put off for years—or even decades—by the pendency of these unnecessary court cases. They employ this period to benefit from collecting the interest and returns on both the premiums previously paid by the insured clients and the insurance proceeds which should otherwise go to their beneficiaries.
Philam Life’s deliberate delay in the payment of insurance proceeds and protracted litigation warrant the imposition of exemplary damages. This imposition serves as a warning to insurers or insurance companies of the consequences of unreasonably denying or delaying the payment of legitimate claims. Hence, aside from the insurance claim, Philam Life was also ordered to pay exemplary damages in the amount of PHP 50,000.00 with interest.
