G.R. No. 205206 . March 16, 2016.
BANK OF THE PHILIPPINE ISLANDS AND FGU INSURANCE CORPORATION (PRESENTLY KNOWN AS BPI/MS INSURANCE CORPORATION), PETITIONERS, VS. YOLANDA LAINGO, RESPONDENT.

FACTS

Rheozel Laingo opened a Platinum 2-in-1 Savings and Insurance account with petitioner Bank of the Philippine Islands (BPI). This product combined a savings deposit with an automatic personal accident insurance policy from co-petitioner FGU Insurance Corporation. A certificate was issued naming his mother, respondent Yolanda Laingo, as the beneficiary. Rheozel died in a vehicular accident on September 25, 2000. Two days later, Laingo, through her secretary, inquired at BPI about Rheozel’s savings to cover funeral expenses. BPI, due to Laingo’s standing, accommodated a withdrawal of P995,000 and even sent an employee to the wake with documents.
The insurance certificate, however, remained undiscovered in Rheozel’s room until his sister found it over two years later, in January 2003. Upon learning of the policy, Laingo filed her insurance claim with FGU in September 2003. FGU denied the claim, citing Paragraph 15 of the certificate, which required written notice of claim to be filed “within three calendar months of death.” Laingo sued for specific performance.

ISSUE

Whether Laingo, as a beneficiary who had no knowledge of the insurance policy’s existence, is bound by the three-month deadline for filing a written notice of claim.

RULING

The Supreme Court ruled in favor of Laingo, affirming the Court of Appeals. The legal logic centers on agency, equity, and the duty to notify. The Court found that BPI acted as the agent of FGU Insurance in marketing and administering the integrated savings-insurance product. Under the law of agency, notice to the agent (BPI) is notice to the principal (FGU). BPI had actual knowledge of Rheozel’s death within days, facilitated through Laingo’s withdrawal inquiry and the visit to the wake. Therefore, FGU was deemed to have been notified within the three-month period.
Crucially, the Court emphasized that BPI, given its direct interactions with Laingo immediately after the death, had multiple opportunities to inform her of the attached insurance policy but failed to do so. It would be unjust to allow the insurer to deny a claim based on the beneficiary’s failure to comply with a contractual deadline about which she was never informed, especially when its own agent possessed the relevant knowledge. Laingo cannot be expected to perform an obligation of which she was utterly unaware. Consequently, FGU is liable to pay the insurance proceeds, and both petitioners are jointly liable for damages due to their failure in their notification duty.