G.R. No. 83376 . May 29, 1989.
STRONGHOLD INSURANCE COMPANY, INC., petitioner, vs. HON. COURT OF APPEALS and FELICITAS RIVERA, respondents.

FACTS

Cesar Rivera, a contract worker in Iraq, was covered by a group personal accident insurance policy issued by Stronghold Insurance Company to his employer, Erectors, Inc. The policy promised a benefit of P75,000 in case of a work-related accidental death. On March 23, 1982, Rivera died. The death certificate from Iraq listed myocardial infarction (heart attack) as the cause. His widow, Felicitas Rivera, filed a claim which Stronghold denied. She then sued before the Insurance Commission.
At the hearing, Felicitas presented an eyewitness, Rudy Buendia, who testified that Rivera died from injuries sustained after tripping, falling, and hitting his head on a concrete floor at work. The Insurance Commission dismissed the complaint, discrediting Buendia’s testimony due to an inconsistency with a prior letter from the employer that mentioned a different accident date. The Court of Appeals reversed this decision, finding Buendia credible and noting that the National Bureau of Investigation’s exhumation report, which revealed fractured ribs, corroborated the claim of an accidental fall. Stronghold appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in finding Cesar Rivera’s death to be accidental and within the coverage of the insurance policy, thereby holding Stronghold liable.

RULING

The Supreme Court affirmed the decision of the Court of Appeals, holding Stronghold liable for the insurance proceeds. The legal logic centered on the proper evaluation of evidence. The Court found that the respondent appellate court correctly appreciated the evidence in favor of the claimant. The Iraqi death certificate, which indicated myocardial infarction, was deemed inconclusive as it was issued merely to facilitate the transport of the remains and did not definitively establish the proximate cause of death. Conversely, the NBI exhumation report, which documented fractured ribs, provided tangible physical evidence consistent with the eyewitness account of a violent fall.
The Court upheld the appellate court’s authority to review and overturn factual findings of the Insurance Commission when the latter’s conclusions were not supported by the evidence. The perceived inconsistency in dates was insufficient to completely discredit the eyewitness, especially when his testimony was bolstered by objective medical findings. Therefore, the claimant successfully proved that death resulted from an accident covered by the policy. However, the Supreme Court deleted the award of attorney’s fees because the Court of Appeals failed to state the justification for it in the body of its decision, as required by jurisprudence.