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  • Philippine American Life Insurance Company Vs CA

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    Karen Jane Palmiano
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    Philippine American Life Insurance Company vs. Court of Appeals PhilAm Life denied a claim on a life insurance policy, arguing the policy was void as it was procured through fraud. The insured, Pulido, was said to have died before applying for the policy based on PhilAm Life's investigation. However, both the trial court and appellate court ruled in favor of the beneficiary, finding the Certificate of Death listing Pulido's date of death in 1991 to be accurate. The Supreme Court upheld this ruling, stating that death certificates are considered prima facie evidence and the petitioner failed to provide sufficient evidence to prove fraud attended the issuance of the policy.

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    Insurance - death certificates - evidence

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    Philippine American Life Insurance Company vs CA

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    Philippine American Life Insurance Company vs. Court of Appeals PhilAm Life denied a claim on a life insurance policy, arguing the policy was void as it was procured through fraud. The insured, Pulido, was said to have died before applying for the policy based on PhilAm Life's investigation. However, both the trial court and appellate court ruled in favor of the beneficiary, finding the Certificate of Death listing Pulido's date of death in 1991 to be accurate. The Supreme Court upheld this ruling, stating that death certificates are considered prima facie evidence and the petitioner failed to provide sufficient evidence to prove fraud attended the issuance of the policy.

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    © All Rights Reserved
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    94 views1 page

    Philippine American Life Insurance Company Vs CA

    Uploaded by

    Karen Jane Palmiano
    Philippine American Life Insurance Company vs. Court of Appeals PhilAm Life denied a claim on a life insurance policy, arguing the policy was void as it was procured through fraud. The insured, Pulido, was said to have died before applying for the policy based on PhilAm Life's investigation. However, both the trial court and appellate court ruled in favor of the beneficiary, finding the Certificate of Death listing Pulido's date of death in 1991 to be accurate. The Supreme Court upheld this ruling, stating that death certificates are considered prima facie evidence and the petitioner failed to provide sufficient evidence to prove fraud attended the issuance of the policy.

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    © All Rights Reserved
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    of 1

    Philippine American Life Insurance Company vs.

    Court of Appeals
    Facts:
    In 1989, Pulido obtained a life insurance from PhilAm Life designating her sister as the
    principal beneficiary. Because the insurance applied for was non-medical, petitioner did not
    require a medical examination and issued a policy on the sole basis of the application. In 1992,
    PhilAm Life received a claim from the beneficiary stating that Pulido died of acute pneumonia
    in 1991. PhilAm Life withheld payment on the ground that the policy was void from the start
    for having been procured in fraud. It contends that even before they received the claim for death
    benefits, their investigation yielded the information that the insured died in 1988, before the
    application for insurance on her life was made. A complaint was then filed before the LC
    seeking payment of the face amount of the policy with interest and damages. To substantiate its
    defense, PhilAm Life submitted copies of the reports of its investigation. However, Philam Life
    failed to discharge the burden of proving that fraud attended the issuance of the policy. The
    respondent, on the other hand, presented as a witness the then Municipal Health Officer who
    authenticated the Certificate of Death of Pulido issued by the Local Civil Registrar. The TC
    rendered its decision in favor of the respondent holding that there is no reason to doubt the
    correctness of the entries in the Certificate of Death, which declared that Pulido died on 1991.
    Issue:
    WON fraud attended the issuance of the policy
    Held:
    The lower courts had ruled upon the preponderance of the evidence duly received from both
    parties. We see no reversible error in the finding of both respondent court and the trial court in
    favor of the correctness of the entries in Certificate of Death.
    Death certificates, and notes by a municipal health officer prepared in the regular performance of
    his duties, are prima facie evidence of facts therein stated.19 A duly-registered death certificate
    is considered a public document and the entries found therein are presumed correct, unless the
    party who contests its accuracy can produce positive evidence establishing otherwise.20
    Petitioners contention that the death certificate is suspect because Dr. Gutierrez was not present
    when Florence Pulido died, and knew of Florences death only through Ramon Piganto, does not
    merit a conclusion of fraud. No motive was imputed to Dr. Gutierrez for seeking to perpetuate a
    falsity in public records. Petitioner was likewise unable to make out any clear motive as to why
    Ramon Piganto would purposely lie. Mere allegations of fraud could not substitute for the full
    and convincing evidence that is required to prove it.21 A failure to do so would leave intact the
    presumption of good faith and regularity in the performance of public duties, which was the basis
    of both respondent court and the trial court in finding the date of Florence Pulidos death to be as
    plaintiff-private respondent maintained.

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