Pineda v Court of Appeals Pineda v Court of Appeals
I. Recit-ready summary Life. Capt. Nuval received these checks and deposited them in his account with the Boston Bank. Eventually, the complainants-appellees learned that Prime Marine Services Inc. (PMSI) signed a group policy with Insular they were entitled, as beneficiaries, to life insurance benefits under a group Life to give PMSI employees life insurance. 6 employees died overseas. policy with Insular Life and wanted to recover these benefits. Insular Life Their families went to the President of PMSI, Capt. Nuval, and signed 5 denied their claim on the ground that their liability to the families was Special Powers of Attorneys, which granted him the power to ‘follow up, already extinguished because of the delivery and receipt by PMSI of the 6 ask, demand, collect, and receive benefit indemnities or sums of money checks issued in the complainant-appellees names. relative to the sinking of the ship’. They were able to receive their death The families filed with the Insurance Commission against Insular Life benefits. However, Capt. Nuval also used these SPAs to receive the life claiming that Insular Life should pay the families’ insurance claims and that insurance benefits by filing formal claims against Insular Life and placed proper sanctions be imposed for reckless violations of the Insurance Code. the checks in his own account. The Insurance Commission decision favored the families ordering The issue is w/n insular life was negligent for giving the checks to 1. Pay a fine of P500.00 a day from the receipt of this decision until Capt Nuval because of the SPAs made by the families. YES actual payment SPAs should be strictly construed. The SPAs made by the families did 2. Pay and settle the claims of Ayo and Lontok, for 50k and 40k not give Capt. Nuval the authority to receive the checks for them. respectively. 3. Notify individual beneficiaries designated under any Group Policy, in the event of the death of insured, where the corresponding claims are II. Facts of the case filed by the policy holder Prime Marine Services Inc (PMSI), a crewing/manning outfit, got a 4. Show cause within ten days why its other responsible officers who hold of Group Policy No. G-004694 from Insular Life Assurance Co., Ltd. have handled this case should not be subjected to disciplinary and to provide life insurance coverage for its seabased employees enrolled other administrative sanctions for deliberately releasing to Capt. under the plan. While the policy was effective, 6 covered employees of the Nuval the check intended for spouses ALARCON, in the absence of PMSI died at sea when their vessel, M/V Nemos (Greek cargo ship), sunk any Special Power of Attorney for that matter and for negligence with somewhere in Morocco. respect to the release of the other five checks. The petitioner families (Pineda, Montenegro, Alarcon, Ayo, Insular Life appealed to the CA, who modified the decision by removing Calumbag, Lontok), after the loss of said loved ones, went to the President the award to Ayo and Lontok. and General Manager of PMSI, Capt. Nuval, to claim the death benefits due them. Capt. Nuval told them to execute special powers of attorney Hence this petition. authorizing Capt. Nuval to demand their benefit indemnities of sums of money due them for the sinking of M/V Nemos. They were able to get their III. Issue/s death benefits. However, without telling the families, PMSI, in its capacity as W/N Insular Life was negligent in relying on the Special Power of Attorney employer and policyholder of the life insurance of its deceased workers, executed by the families to let Capt. Nuval receive the 6 checks? YES filed with Insular Life formal claims for and in behalf of the beneficiaries, through Capt. Nuval. 5 Special Powers of Attorney documents executed by IV. Ratio/Legal Basis the families (except Alarcon) were used as part of the claims. Based on DOCTRINE: Special Powers of Attorney should be strictly construed. these documents, Insular Life withdrew from its account with the Bank of Different from General Power of Attorney or universal agency. the Philippines 6 checks: 4 for P200k each, 1 for P50k, 1 for P40k. These checks were released to PMSI upon instructions of Capt. Nuval with Insular USED IN CASE:
G.R. NO: 105562 PONENTE: Davide, Jr., J:
ARTICLE; TOPIC OF CASE: Special Powers of Attorney: Any other act of strict Dominion DIGEST MAKER: Simpson B2022 REPORTS ANNOTATED VOL 32 [September 27 1993]
Pineda v Court of Appeals Pineda v Court of Appeals
“To follow-up, ask, demand, collect and receipt for my benefit indemnities people, namely, the employees or the beneficiaries. Employers use these or sum of money due me relative to the sinking of M.V. NEMOS in the group policies and advertise them as “employee benefits.” The way vicinity of El Jadida, Casablanca, Morocco on the evening of February 17, insurance is paid is through the service of the employee to the employer, 1986; and which the employer deducts from the wages. If some death happens, employee goes to employer for the benefits, NOT the insurance dudes. The To sign receipts, documents, pertinent waivers of indemnities or other employer is the agent for the insurance dudes. writings of whatsoever nature with any and all third persons, concerns and entities, upon terms and conditions acceptable to my said attorney” Insular Life is the Insurer Dudes (document made by the families) PMSI is the Employer/Policy Holder Families is the Employees/ Beneficiaries These words cannot be construed to authorize Capt. Nuval the power to receive the proceeds arising from the death of the seaman-insured or the Problem, Insular gave it straight to beneficiaries when Capt nuval beneficiaries. This is especially true considering that the common practice (representing the families, not PMSI) asked for the proceeds. Thus Insular between insurance companies and policy holders (employers) that the was negligent. policy holders collect the proceeds on behalf of the covered insured or their beneficiaries. Insular knew that a power of attorney in favor of Capt. Nuval for the collection and receipt of such proceeds was a deviation from its practice with respect to group policies.
V. Disposition
WHEREFORE, the instant petition is GRANTED. The Decision of 10
October 1991 and the Resolution of 19 May 1992 of the public respondent in CA-G.R. SP No. 22950 are SET ASIDE and the Decision of the Insurance Commission in IC Case No. RD-058 is REINSTATED
VI. Notes
In the cross examination, atty ampil was grilling the witness for Insular in this case. Apparently, as according to their standard policy, Insular should only give the checks to the policy holder (PMSI) but they gave it to the beneficiaries/families through Capt Nuval, who was empowered to be the agent of the families. Insular does not need a power of attorney to give the checks to the policy holder.
Basic relationship between insurance dudes and employers
Insurance dudes sign “group policies” with employers. Employers are
now the policy holders. It’s a one time contract to cover a large group of
G.R. NO: 105562 PONENTE: Davide, Jr., J:
ARTICLE; TOPIC OF CASE: Special Powers of Attorney: Any other act of strict Dominion DIGEST MAKER: Simpson
