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VIOLETA R. LALICAN v. INSULAR LIFE ASSURANCE COMPANY LIMITED

FACTS:

The case involves a claim for death benefits filed by petitioner Violeta R. Lalican against respondent Insular Life Assurance Company Limited. Violeta is the widow of Eulogio C. Lalican, who had an insurance policy with Insular Life. The policy lapsed and became void when Eulogio failed to pay the premium on time. He submitted an application for reinstatement, but passed away before it could be fully processed. Violeta filed a claim for the proceeds of the policy, but Insular Life denied the claim, stating that the policy had already lapsed and Eulogio failed to reinstate it. Insular Life refunded the payments made by Eulogio and refused to reconsider the denial of Violeta's claim. Violeta filed a complaint in the RTC, alleging unfair claim settlement practices and seeking payment of the death benefits.

Violeta filed a complaint against Insular Life Insurance Company, seeking the promptness of her insurance claim for the death benefits on Policy No. 9011992. Insular Life filed an Answer with Counterclaim, arguing that the policy was void due to non-payment of the premium and non-compliance with reinstatement requirements. Violeta replied, denying Insular Life's claims. After trial, the RTC ruled in favor of Insular Life, finding that the policy had lapsed and the requirements for reinstatement were not fully complied with.

Violeta filed a complaint against Insular Life, alleging that her late husband, Eulogio, applied for the reinstatement of his lapsed insurance policy and submitted the payment of overdue premiums and interest to the company's agent. However, Eulogio passed away a day before the application for reinstatement. Violeta claimed that the payment made by Eulogio should be considered as an automatic reinstatement of the policy.

The Regional Trial Court (RTC) dismissed Violeta's complaint, stating that there was no evidence to support the automatic renewal of the policy. The court emphasized that the payment of premiums and interest does not automatically reinstate the policy, and the agent who received the payment was not authorized to approve the application for reinstatement.

Violeta filed a motion for reconsideration, but it was denied by the RTC. Despite receiving the denial order, Violeta filed a reply to the motion for reconsideration and a reply extended discussion detailing her arguments.

ISSUES:

  1. Whether or not the Decision of the RTC dated August 30, 2007, can still be reviewed despite allegedly attaining finality and the fact that the mode of appeal availed of by Violeta is erroneous.

  2. Whether or not the RTC in its original jurisdiction decided the case on a question of law not in accord with law and applicable decisions of the Supreme Court.

RULING:

  1. No, the Decision of the RTC dated August 30, 2007, cannot be reviewed as it has already attained finality. The Notice of Appeal was filed beyond the reglementary period, and the excuses provided by Violeta regarding her former counsel's poor health were unpersuasive and unsupported by evidence.

  2. No, the Petition lacks merit even on substantive grounds. Eulogio's policy had lapsed, and he failed to comply with the terms for reinstatement before his death. Hence, the RTC's decision was consistent with the law and applicable decisions of the Supreme Court.

PRINCIPLES:

  1. Finality of Judgment: A judgment becomes final and executory by operation of law when the period to appeal lapses without an appeal being perfected. Once final, the judgment is immutable and unalterable.

  2. Client's Responsibility for Counsel's Actions: A client is bound by the acts and mistakes of his counsel, and allegations of counsel’s poor health must be substantiated.

  3. Conditions for Reinstatement of Insurance Policy: Reinstatement requires not only the submission of an application and payment of overdue premiums but also the approval of the insurer during the insured's lifetime and good health.

  4. Insurable Interest: This must exist when the insurance takes effect but need not exist thereafter or when the loss occurs.

  5. Non-Ambiguity in Insurance Contracts: Clear, unequivocal, and unmistakable terms in insurance policies do not require construction and must be enforced as written.

  6. Authority of Insurance Agents: Insurance agents typically have no authority to modify contracts or waive company requirements unless expressly authorized in writing.