GR 194328; (July, 2015) (Digest)
G.R. No. 194328 July 1, 2015
STRONGHOLD INSURANCE COMPANY, INCORPORATED, Petitioner, vs. INTERPACIFIC CONTAINER SERVICES and GLORIA DEE CHONG, Respondents.
FACTS
Respondent Gloria Dee Chong owned a Fuso truck insured by petitioner Stronghold Insurance Company under a comprehensive motor car insurance policy. While the policy was in effect, the vehicle figured in an accident resulting in deaths, injuries, and property damage. Respondent Chong filed a claim for ₱550,000.00 under the policy. The insurance company denied the claim on the ground that the driver of the insured vehicle was heavily drunk at the time of the accident, as shown by a Pagpapatunay issued by a Barangay Chairman and a Medico Legal Certificate. Respondents filed a complaint for recovery of sum of money. The Regional Trial Court (RTC) ruled in favor of respondents, ordering petitioner to pay the insurance claim, plus interest, exemplary damages, attorney’s fees, and costs. The Court of Appeals affirmed the RTC decision but deleted the award for exemplary damages. The appellate court found the evidence presented by the petitioner (the Medico Legal Certificate and Pagpapatunay) to be hearsay and without evidentiary value, and noted the absence of any mention of driver intoxication in the police blotter report.
ISSUE
Whether or not it was proven during the trial that the driver of the insured vehicle was intoxicated at the time of the accident, thereby precluding the respondents from claiming the proceeds of the insurance policy.
RULING
The Supreme Court DENIED the petition and AFFIRMED the Decision of the Court of Appeals. The Court held that the petitioner failed to prove by clear, credible, and convincing evidence that the driver was intoxicated. The Medico Legal Certificate was found to have been tampered with, and the petitioner did not present additional evidence, such as affidavits from witnesses, to buttress its claim. The lack of any statement regarding intoxication in the police blotter report was deemed significant. The Court reiterated that factual findings of the trial court are entitled to respect and that the party alleging a violation of the insurance contract bears the burden of proof. Since the petitioner failed to discharge this burden and the respondents duly established their right to claim under a valid subsisting contract, the petitioner is liable to pay the insurance claim.