Magbojos - Mitsubishi Motors Philippines Salaried Employees Union v. Mitsubishi Motors Philippines Corporation - 4D

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Magbojos, Kristine V.

TOPIC: Double Insurance

MITSUBISHI MOTORS PHILIPPINES SALARIED EMPLOYEES UNION (MMPSEU) v.


MITSUBISHI MOTORS PHILIPPINES CORPORATION (MMPC)
GR 175773 | June 17, 2013
Del Castillo, J.

DOCTRINE: The principle of indemnity which proscribes the insured from recovering greater
than the loss. Indeed, to profit from a loss will lead to unjust enrichment and therefore should
not be countenanced.

FACTS: CBA of the parties provides that the company shall shoulder the hospitalization
expenses of dependents of covered employees. The latter pay part of the hospitalization
insurance premium through salary deduction. 3 members filed claims for reimbursement of
hospitalization expenses but MMPC only paid for the amounts not covered by other insurance
companies and those covered by official receipts. The union insists that the members are
entitled to the whole and undiminished amount which should not be reduced by the amounts
paid by insurance companies. MMPC counters that such will result to double insurance.

ISSUE: Will the reimbursement of the full amount of the hospitalization expenses by the
employer under the CBA including those amounts already covered by health insurance
companies will result to double insurance?

RULING: Yes. The principle of indemnity which proscribes the insured from recovering greater
than the loss. Indeed, to profit from a loss will lead to unjust enrichment and therefore should
not be countenanced. In the present case, the condition that payment should be direct to the
hospital and doctor implies that MMPC is only liable to pay medical expenses actually
shouldered by the employees’ dependents and does not include the amounts paid by other
health insurance providers. This condition is obviously intended to thwart not only fraudulent
claims but also double claims for the same loss of the dependents of covered employees.

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