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Philippine American Life Insurance Company Vs CA
Philippine American Life Insurance Company Vs CA
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.