FACTS:

The case involves the payment of an insurance claim under a personal accident policy. Felix Lim, Jr. obtained a policy with a face value of P200,000.00, designating his wife, Nerissa Lim, as the beneficiary. Two months after obtaining the policy, Felix was found dead with a bullet wound in his head. Nerissa filed a claim on the policy, but it was rejected by the insurance company, arguing that there was no accident involved in Felix's death. The sole eyewitness, Pilar Nalagon, Felix's secretary, testified that Felix was playing with his handgun before the incident occurred. Felix pointed the gun at her, pushed it aside, and assured her it was not loaded. He then pointed it to his temple, resulting in an explosion that caused his death. The trial court ruled in favor of Nerissa Lim and ordered the insurance company to pay the claim and damages. The decision was upheld on appeal, prompting the insurance company to file a petition with the Supreme Court. The insurance company argued that there was no accident, but willful exposure to needless peril, which would exclude coverage based on the policy's exceptions. The Supreme Court, however, held that the incident was indeed an accident, and the unexpected and independent occurrence of the gun firing caused Felix's death.

ISSUES:

1. Whether the incident that resulted in Lim's death was an accident.

2. Whether Lim willfully exposed himself to needless peril.

RULING:

1. The incident that resulted in Lim's death was an accident. An accident is defined as an event that happens by chance or fortuitously, without intention or design, and which is unexpected, unusual, and unforeseen. In this case, the firing of the gun, which led to Lim's death, was an additional unexpected and independent occurrence that qualifies as an accident.

2. Lim did not willfully expose himself to needless peril. While suicide and willful exposure to needless peril both signify a disregard for one's life, the difference lies in the degree. Suicide involves a positive act of ending one's life, while willful exposure to needless peril indicates a reckless risking of one's life. In this case, Lim did not commit suicide, but rather engaged in a reckless act. Therefore, Lim's willful exposure to needless peril does not remove him from the coverage of the insurance policy.

PRINCIPLES:

• The term "accident" is defined as an event that happens by chance or fortuitously, without intention or design, and which is unexpected, unusual, and unforeseen.

• Willful exposure to needless peril signifies a reckless risking of one's life that is almost suicidal in intent.