G.R. No. 240320, May 22, 2024
THE PHILIPPINE AMERICAN LIFE AND GENERAL INSURANCE [PHILAM LIFE] COMPANY AND PABLITO BAIS, PETITIONERS, VS. ROMEO D. SORIANO AND MARIA LUISA R. SORIANO, RESPONDENTS.

FACTS

Respondent Romeo D. Soriano, an account executive, held multiple accident insurance policies from various companies, including petitioner Philam Life. On January 29, 2001, he claimed he tripped exiting a bathroom, causing his right eye to hit a chair’s armrest. He was brought to a clinic and subsequently admitted to a hospital where he underwent an enucleation (surgical removal) of his right eye. He filed claims with all his insurers. The claims were disapproved based on a joint affidavit from two former household helpers, secured by petitioner Pablito Bais (an investigator) and another adjuster, which denied the accident occurred. The spouses Soriano filed separate complaints before the Regional Trial Court (RTC) against the insurance companies and Bais for insurance proceeds, damages, etc. The RTC dismissed the complaints based on the equipoise rule. The Court of Appeals (CA) reversed the RTC, finding the spouses Soriano’s evidence more credible. The CA directed the insurance companies to pay jointly and severally the medical expenses and the appropriate insurance proceeds for the permanent loss of sight. It affirmed the dismissal of the complaint against Bais for lack of evidence of malice. Philam Life and Bais filed the present Petition.

ISSUE

Whether the Court of Appeals erred in reversing the RTC and ruling that respondents are entitled to the accident insurance proceeds, thereby rejecting the application of the equipoise rule and finding the respondents’ evidence preponderant.

RULING

The Supreme Court denied the Petition and affirmed the Decision of the Court of Appeals. The Court held that the CA correctly found that the respondents proved by preponderance of evidence that Romeo’s injury was caused by an accident. The issues raised were factual, but an exception applied as the findings of the CA and RTC were conflicting. The Court ruled that the equipoise rule was inapplicable because the respondents’ evidence was superior. The testimonies of the spouses Soriano, who were cross-examined, were not merely self-serving as they were subject to adversarial testing. Their account was corroborated by the testimony and medical findings of Dr. Reynaldo Villanueva, the attending physician who performed the enucleation. The affidavit of the helper, Rofe Dellera, was undermined by her admission that she saw Romeo with a plaster on his right eye on the date of the alleged accident. The Court found no merit in Philam Life’s argument that the medical findings were insufficient, as the opinion of its own expert, Dr. Valenton, did not categorically state the injury was not accidental. Consequently, the respondents were entitled to the insurance proceeds under the policies. The dismissal of the case against Bais was also sustained.