FACTS:

The petitioner issued five insurance policies to the respondent, covering various properties against fire from May 22, 1991, to May 22, 1992. In March 1992, the petitioner decided not to renew the policies upon expiration and informed the respondent's broker of this decision. On April 6, 1992, the petitioner sent a written notice of non-renewal to the respondent. However, in July 1992, the respondent tendered premium payment for the renewal of the policies, which the petitioner rejected. On June 13, 1992, a fire occurred, damaging the insured property. The respondent filed a claim for indemnification, which the petitioner denied.

ISSUES:

1. Whether the fire insurance policies issued by the petitioner to the respondent had expired on May 22, 1992, or had been extended or renewed by an implied credit arrangement, despite the actual payment of the premium being tendered after the occurrence of the insured risk (fire).

RULING:

The Supreme Court ruled that an insurance policy, other than life insurance, is not valid and binding until the actual payment of the premium. Any agreement to the contrary is void. Therefore, the insurance policies had expired on May 22, 1992, and were not extended or renewed. Additionally, the court found that the payment of the premium for the renewal of the policies was tendered after the fire occurred, and no timely notice of loss was given. Consequently, the decision of the Court of Appeals was reversed, and the respondent's complaint was dismissed.

PRINCIPLES:

1. Insurance Code Principle: An insurance policy, other than life insurance, is not valid and binding until the actual payment of the premium. Agreements to the contrary are void.

2. Contract of Insurance Doctrine: Parties may not agree expressly or impliedly on the extension of credit or time to pay the premium and consider the policy binding before actual payment.