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Vitug Facts: Valenzuela Hardwood entered into an agreement with the defendant Seven Brothers whereby the latter undertook to load the former's 940 lauan logs for shipment to Manila. South Sea insured the logs for P2,000,000.00 in its marine policy. Valenzuela then gave the check in payment of the premium on the insurance policy to Mr. Victorio Chua. Seven Brothers’ ship sank resulting in the loss of the logs. A check for P5,625.00 to cover payment of the premium tendered to the insurer but was not accepted. Instead, the South Sea Surety and Insurance Co., Inc. cancelled the insurance policy it issued as of the date of inception for non-payment of the premium due in accordance with Section 77 of the Insurance Code. Valenzuela demanded from South Sea the payment of the proceeds of the policy but the latter denied liability under the policy. Plaintiff likewise filed a formal claim with defendant Seven Brothers Shipping Corporation for the value of the lost logs but the latter denied the claim. Valenzuela filed a complaint a complaint for the recovery of the value of lost logs and freight charges from Seven Brothers Shipping Corporation or from South Sea Surety and Insurance Company, the insurer. The trial court rendered judgment in favor of plaintiff Valenzuela. The Court of Appeals affirmed the judgment only against the insurance corporation and absolved the shipping entity from liability. The court held that there was a stipulation in the charter party exempted the ship owner from liability in case of loss. In the SC petition, petitioner argues that it should have been freed from any liability to Hardwood. It faults the appellate court (a) for having disregarded Section 77 of the insurance Code and (b) for holding Victorio Chua to have been an authorized representative of the insurer. Issue: WON Mr. Chua acted as an agent of the surety company or of the insured when he received the check for insurance premiums. Held: Agent of the surety. Petition denied. Ratio: To determine if there was a valid contract of insurance, it must be determine if the premium was validly paid to the company or its agents at the time of the loss. The appellate and trial courts have found that Chua acted as an agent. South Sea insisted that Chua has been an agent for less than ten years of the ColumbiaInsurance Brokers, a different company. Appellant argued that Mr. Chua, having received the premiums, acted as an agent under Section 301 of the Insurance Code which provides: Sec. 301. Any person who for any compensation, commission or other thing of value, acts, or aids in soliciting, negotiating or procuring the making of any insurance contract or in placing risk or taking out insurance, on behalf of an insured other than himself, shall be an insurance brokerwithin the intent of this Code, and shall thereby become liable to all the duties requirements, liabilities and penalties to which an insurance broker is subject. Valenzuela claimed that the second paragraph of Section 306 of the Insurance Code provided: Sec. 306 Any insurance company which delivers to an insurance agent or insurance broker a policy or contract of insurance shall be deemed to have authorized such agent or broker to receive on its
behalf payment of any premium which is due on such policy of contract of insurance at the time of its issuance or delivery or which becomes due thereon. Mr. Chua testified that the marine cargo insurance policy logs was by South Sea to be given to the wood company. When South Sea delivered to Mr. Chua the marine cargo insurance policy for Valenzuela’s logs, he is deemed to have been authorized by former to receive the premium which is due on its behalf. When the logs were lost, the insured had already paid the premium to an agent of the South SeaSurety and Insurance Co., Inc., which is consequently liable to pay the insurance proceeds under the policy it issued to the insured. The court followed the factual evidence of the lower courts and held that they didn’t try questions of fact. TANG V. CA- INSURANCE FRAUD OR MISTAKE 90 SCRA 236 Facts: On Sept. 25, 2965, Lee Su Guat, widow, 61 years old and illiterate who spoke only Chinese, applied for life insurance for 60T with Philamlife. The application was in two parts, both in English. The second part dealt with her state of health. Her answers having shown that she was health, Philamlife issued her a policy effective Oct. 23, 1965 with her nephew Vicente Tang as beneficiary. On Nov. 15, 1965, Lee again applied for additional insurance of her life for 40T. Since it was only recent from the time she first applied, no further medical exam was made but she accomplished Part 1 (which certified the truthfulness of statements made in Part. 2) The policy was again approved. On Apri 20 1966, Lee Su Guat died of Lung cancer. Tang claimed the amount o 100T but Philamlife refused to pay on the ground that the insured was guilty of concealment and misrepresentation. Both trial court and CA ruled that Lee was guilty of concealment. Tang’s position, however, is that because Lee was illiterate and spoke only Chinese, she could not be held guilty of concealment of her health history because the application for insurance was English, and the insurer has not proven that the terms thereof had been fully explained to her as provided by Art. 1332 of CC. Issue: Whether or not Art. 1332 applies. Held: NO. Art. 1332 is NOT applicable. Under said article, the obligation to show that the terms of the contract had been fully explained to the party who is unable to read or understand the language of the contract, when fraud or mistake is alleged, devolves on the party seeking to enforce it. Here, the insurance company is NOT seeking to enforce the contract; on the contrary, it is seeking to avoid its performance. It is petitioner who is seeking to enforce it, even as fraud or mistake is NOT alleged. Accordingly, Philamlife was under no obligation to prove that the terms of the insurance contract were fully explained to the other party. Even if we were to say that the insurer is the one
Sec 31) The terms of the contract are clear. the insured died in a plane crash. > In its letter. Neither does materiality depend upon the actual or physical events which ensue. thus rendering the contract of insurance voidable. seeking the benefits of the insurance. the information concealed must be information which the concealing party knew and "ought to [have] communicate[d]. The insured is specifically required to disclose to the insurer matters relating to his health. Bacani procured a life insurance contract for himself from Sun Life. except through proof of external acts or failure to act from which inferences as to his subjective belief may be reasonably drawn. required a higher premium for the same coverage. Materiality relates rather to the "probable and reasonable influence of the facts" upon the party to whom the communication should have been made. as his beneficiary. Moreover. all facts within his knowledge which are material to the contract and as to which he makes no warranty. it has to be noted as above stated that there has been NO imputation of mistake of fraud by the illiterate insured whose personality is represented by her beneficiary. by the judge ultimately. Canilang consulted the same doctor again on 3 August 1982 and this time was found to have "acute bronchitis. The materiality of the information withheld by Canilang from Grepalife did not depend upon the state of mind of Jaime Canilang. DE CANILANG V. Had Canilang disclosed his visits to his doctor." > On the next day.seeking the performance of the cont contracts by avoiding paying the claim. it may be reasonably assumed that Grepalife would have made further inquiries and would have probably refused to issue a non-medical insurance policy or. of course. where he was diagnosed for renal failure.CONCEALMENT 223 SCRA 443 (1993) Facts: > Canilang consulted Dr. Issue: Whether or not the beneficiary can claim despite the concealment. VDA. filed an action for specific performance against Sun Life. > Grepalife was ordered to pay the widow by the Insurance Commissioner holding that there was no intentional concealment on the Part of Canilang and that Grepalife had waived its right to inquire into the health condition of the applicant by the issuance of the policy despite the lack of answers to "some of the pertinent questions" in the insurance application. filed a claim with Grepalife which the insurer denied on the ground that the insured had concealed material information from it. It appears that such concealment was deliberate on his part. the deceased was subjected to urinalysis. A man's state of mind or subjective belief is not capable of proof in our judicial process." "anemia. SUN LIFE V. In sum. Canilang applied for a "nonmedical" insurance policy with Grepalife naming his wife." Mr. and considering the findings of both the trial court and the CA as to the Concealment of Lee. Issue: Whether or not Grepalife is liable. 1332 is inapplicable. > Vda Canilang filed a complaint with the Insurance Commissioner against Grepalife contending that as far as she knows her husband was not suffering from any disorder and that he died of kidney disorder. During his confinement. it held that the health history of the insured was immaterial since the insurance policy was "non-medical. Sun Life informed Berarda. Claudio who had found him to be suffering from "sinus tachycardia" and "acute bronchitis. The designated beneficiary was his mother. but solely by the probable and reasonable influence of the facts upon the party to whom communication is due. and which the other has no means of ascertaining. ultra-sonography and hematology tests. that "probable and reasonable influence of the facts" concealed must. Bernarda Bacani filed a claim with Sun Life. Art. The insured's failure to disclose the fact that he was hospitalized for two weeks . raises grave doubts about his bonafides. prior to filing his application for insurance. Held: SC took note of the fact that Canilang failed to disclose that hat he had twice consulted Dr. Wilfredo B. in assessing the risk involved in making or omitting to make further inquiries and in accepting the application for insurance. > On June 26. 4 August 1982. Canilang died of "congestive heart failure.CONCEALMENT IN INSURANCE 245 SCRA 268 (1995) Facts: > On April 15." CA affirmed. Canilang was issued ordinary life insurance with the face value of P19. A check representing the total premiums paid in the amount of P10. Materiality is to be determined not by the event. Sun Life conducted an investigation and its findings prompted it to reject the claim. 1987. Held: NOPE. Section 26 of the Insurance Code is explicit in requiring a party to a contract of insurance to communicate to the other. CA . Claudio and was diagnosed as suffering from "sinus tachycardia. the SC affirms their decisions. > On 5 August 1983. that the insured did not disclosed material facts relevant to the issuance of the policy. Bacani was examined and confined at the Lung Center of the Philippines. The matters concealed would have definitely affected petitioner's action on his application. Moreover. CA reversed. at the very least.172. He was issued a life insurance policy with double indemnity in case of accidental death. be determined objectively. He did not reveal such fact in his application. Bernarda.700." The wife as beneficiary. a disclosure may have warranted a medical examination of the insured by petitioner in order for it to reasonably assess the risk involved in accepting the application." and "chronic anemia. in forming his estimate of the disadvantages of the proposed contract or in making his inquiries (The Insurance Code. > Bernarda and her husband. in good faith. The information which the insured failed to disclose were material and relevant to the approval and the issuance of the insurance policy. 1986. CA . either by approving it with the corresponding adjustment for a higher premium or rejecting the same. The information which Canilang failed to disclose was material to the ability of Grepalife to estimate the probable risk he presented as a subject of life insurance. > Sun Life discovered that 2 weeks prior to his application. information which was "material to the contract.00 was attached to said letter. the diagnosis made and the medicines prescribed by such doctor. Under the relevant provisions of the Insurance Code. Thus. RTC ruled for Bernarda holding that the facts concealed by the insured were made in good faith and under the belief that they need not be disclosed. in the insurance application." that is to say. "good faith" is no defense in concealment.
The company records show that the deceased was examined by Dr. barred from proving that the policy is void ab initio by reason of the insured's fraudulent concealment or misrepresentation. Petition Granted Ratio: 1. Tan Lee Siong died of hepatoma. Facts: Tan Lee Siong. he said that he had no knowledge of the provision in the private respondent's policy requiring him to inform it of the prior policies and this requirement was not mentioned to him by the private respondent's agent. He was also found to have suffered from hepatoma. 114427 February 6.000 issued by PFIC. But. 1989 J. applied for life insurance in the amount of P 80. No. The Court of Appeals dismissed ' the petitioners' appeal from the Insurance Commissioner's decision for lack of merit. provided however.” The so-called "incontestability clause" in the second paragraph prevents the insurer from raising the defenses of false representations insofar as health and previous diseases are concerned if the insurance has been in force for at least two years during the insured's lifetime. the insurer cannot prove that the policy is void ab initio or is rescindable by reason of the fraudulent concealment or misrepresentation of the insured or his agent.00 under fire insurance policy and damages. Ratio: The Insurance Code states in Section 48: “Whenever a right to rescind a contract of insurance is given to the insurer by any provision of this chapter. Such failure precisely constituted concealment on the part of Canilang. The policy noted the requirement that "3. The basis of the private respondent's denial was the petitioner's alleged violation of Condition 3 of the policy. CA reversed the decision of the Insurance Commission because it found that the petitioner knew of the existence of the two other policies issued by the PFIC. Hence.SC found it difficult to take seriously the argument that Grepalife had waived inquiry into the concealment by issuing the insurance policy notwithstanding Canilang's failure to set out answers to some of the questions in the insurance application. Considering that the insured died before the two-year period had lapsed.R.00. 48049 June 29. It was approved. His letter of 18 January 1991 to the private respondent conclusively proves this knowledge. WON he is prohibited from recovering Held: Yes. respondent company is not. or which may subsequently be effected. No. The Insurance Commission found that the petitioner did not violate Condition 3 as he had no knowledge of the existence of the two fire insurance policies obtained from the PFIC.00 with interest and attorney’s fees. 2. The "incontestability clause" added by the second paragraph of Section 48 is in force for two years. Facts: Geagonia.000. Petitioners then filed a claim for the proceeds. WON the petitioner had not disclosed the two insurance policies when he obtained the fire insurance and thereby violated Condition 3 of the policy. They also argue that no evidence was presented by respondent company to show that the questions appearing in Part II of the application for insurance were asked.000.000. Petition dismissed. Petitioner's argument. the defenses of concealment or misrepresentation no longer lie.000. and that Cebu Tesing Textile. covering any of the property or properties consisting of stocks in trade. After a policy of life insurance made payable on the death of the insured shall have been in force during the lifetime of the insured for a period of two years from the date of its issue or of its last reinstatement. explained to and understood by the deceased so as to prove concealment on his part. owner of a store. by or on behalf of the Company before the occurrence of any loss or damage. The petitioners argue that no evidence was presented to show that the medical terms were explained in a layman's language to the insured. would obviously erase Section 27 from the Insurance Code of 1978. the company was thus misled into accepting the risk and approving his application as medically fit. He claimed that he knew the existence of the other two policies. Because of the concealment made by the deceased. He then filed a claim which was subsequently denied because the petitioner’s stocks were covered by two other fire insurance policies for Php 200.000. After this. The 1 year policy and covered thestock trading of dry goods.R. and unless notice be given and the particulars of such insurance or insurances be stated therein or endorsed in this policy pursuant to Section 50 of the Insurance Code. The court agreed with the CA that the petitioner knew of the prior policies issued by the PFIC. Victoriano Lim and was found to be diabetic and hypertensive. Geagonia v CA G. He affirmed the correctness of all the entries. therefore.00 with Philamlife. father of the petitioners. 1995 Tan v CA G. had insurable interest on the stocks. Issue: WON Philam didn’t have the right to rescind the contract of insurance as rescission must allegedly be done during the lifetime of the insured within two years and prior to the commencement of action. that this condition shall not apply when the total insurance orinsurances in force at the time of the loss or damage is not more than P200. The petitioners filed a complaint in the Insurance Commission. Gutierrez Jr. Issues: 1. The latter dismissed the complaint. His . This couldn’t be accepted because the insured signed the form. No." The petitioners’ stocks were destroyed by fire. Geagonia then filed a complaint against the private respondent in the Insurance Commission for the recovery of P100. The insured shall give notice to the Company of any insurance or insurances already effected. as his creditor. all benefits under this policy shall be deemed forfeited. The company denied petitioners' claim and rescinded the policy by reason of the alleged misrepresentation and concealment of material facts. such right must be exercised previous to the commencement of an action on the contract. if accepted. The policy was in force for a period of only one year and five months. obtained from Country Bankers fire insurance policy for P100. this petition. The premiums paid on the policy were refunded. goods in process and/or inventories only hereby insured.00. Held: No. that it was Cebu Tesing Textiles w/c procured the PFIC policies w/o informing him or securing his consent. The Insurance Commission then ordered the respondent company to pay complainant the sum ofP100.
Hence. Issues: 1. that in case the mortgagor or owner/ trustee neglects or refuses to pay any premium.00 with Victory.00) and the goods described in the policy were held in trust by the insured for Pacific Banking under trust receipts. When a property owner obtains insurance policies from two or more insurers in a total amount that exceeds the property's value. With these principles in mind.testimony to the contrary before the Insurance Commissioner and which the latter relied upon cannot prevail over a written admission made ante litem motam. on demand pay the same. Stated differently. Petition dismissed. or in the very least. The public as well as the insurer is interested in preventing a situation in which a fire would be profitable to the insured.000. and (b) the nullity of the policy shall only be to the extent exceeding P200.000. 3 in the policy in relation to the "other insurance clause" supposedly to have been violated. 2. the mortgagee/ trustor shall. Policy Condition No. the total absence of such notice nullifies the policy. The bank sent a letter of demand to Oriental for indemnity. was also not pleaded in the Motion to Dismiss. 1988 J. Condition 3 of the subject policy is not totally free from ambiguity and must be meticulously analyzed.000. It is obvious that petitioner has missed all together the import of subject mortgage clause which specifically provides: “Loss.000 with Asian Surety undertaken by insured Paramount on the same property covered by its policy with Oriental whereas the only co-insurances declared in the subject policy are those of P30. 3 2. but this was denied for lack of merit. P25.00 against Oriental Assurance. conditions or exceptions in policies which tend to work a forfeiture of insurance policies should be construed most strictly against those for whose benefits they are inserted. Concealment of the aforecited co-insurances can easily be fraud.00 with Malayan P50.misrepresentation. cannot be invalidated. The insured failed to reveal before the loss three other insurances. caused by fire to the factory’s stocks. shall be payable to the PACIFIC BANKING CORPORATION Manila mortgagee/trustor as its interest may appear. The company then made an excuse that the insured had not filed any claim with it. WON unrevealed co-insurances Violated policy conditions No. the rationale behind the incorporation of "other insurance" clause in fire policies is to prevent over-insurance and thus avert the perpetration of fraud. was issued to Paramount Shirt Manufacturing by Oriental Assurance Corporation to indemnify P61. Held: Yes.11. The defense of fraud. all benefit under this policy shall be forfeited. and most favorably toward those against whom they are intended to operate. it could have hesitated or plainly desisted from entering into such contract. provided. Concrete evidence of fraud or false declaration by the insured was furnished by the petitioner itself when the facts alleged in the policy under clauses "Co-Insurances Declared" and "Other Insurance Clause" are materially different from the actual number of coinsurances taken over the subject property. the insured may have an inducement to destroy the property for the purpose of collecting the insurance. indeed.” The paragraph clearly states the exceptions to the general rule that insurance as to the interest of the mortgagee. It was.00. Such analysis leads us to conclude that (a) the prohibitionapplies only to double insurance.000. provisions. cannot certainly defeat the right of the petitioner to recover the insurance as mortgagee/assignee. nor submitted proof of loss which is a clear violation of Policy Condition No. Hence. The trial court denied the respondent’s motion. and unless such notice be given and the particulars of such insurance or insurances be stated in or endorsed on this Policy by or on behalf of the Company before the occurrence of any loss or damage. Indeed. WON the insured failed to file the required proof of loss prior to court action. Pacific v CA G. Had the insurer known that there were many co-insurances. At the trial. or arson—of the mortgagor or owner/trustee of the property insured. the insured was guilty of clear fraud. The Insured shall give notice to the Company of any insurance already effected. No. Paras Facts: An open fire insurance policy.00. the private respondent wasamenable to assume a co-insurer's liability up to a loss not exceeding P200. A fire broke out on the premises destroying the goods contained in the building. The policy was endorsed to Pacific Banking as mortgagee/ trustor of the properties insured. The insured was a debtor of Pacific Banking in the amount of (P800. Furthermore.000 with Wellington Insurance. The company wasn’t ready to give since it was awaiting the adjuster’s report.000.00 of the total policies obtained. 3 explicitly provides: 3. materials and supplies.000.00.000 with Empire Surety and P250.000. if any. they claimed that the purpose for which the endorsement or assignment was made was to protect the mortgagee/assignee against any untoward act or omission of the insured. as a result.000. with the knowledge and consent of private respondent to the effect that "loss if any under this policy is payable to the Pacific Banking Corporation". covering any of the property hereby insured. namely: fraud. Ratio: 1. in the form of non-declaration of coinsurances which was not pleaded in the answer. shall not be invalidated by any act or neglect—except fraud or misrepresentation. As the insurance policy against fire expressly required that notice should be given by the insured of other insurance upon the same property. . It would be absurd to hold that petitioner is barred from recovering the insurance on account of the alleged violation committed by the insured. petitioner presented communications of the insurance adjuster to Asian Surety revealing undeclared coinsurances with the following: P30.R. Pacific Banking filed in the trial court an action for a sum of money for P61. Petitioner points out that Condition No.000. or misrepresentation or arson. incredible that he did not know about the prior policies since these policies were not new or original. L-41014 November 28. determination of the liability of private respondent could not be made. Oriental filed another motion to include additional evidence of the co-insurance which could amount to fraud. The CA reversed the trial court decision. it being hereby understood and agreed that this insurance as to the interest of the mortgagee/trustor only herein. under this policy. by stating within Condition 3 itself that such condition shall not apply if the total insurance in force at the time of loss does not exceed P200.00 with South Sea and P25. The trial court still made Oriental liable for P 61. Pacific Banking filed a motion for reconsideration of the said decision of the respondent Court of Appeals. or which may subsequently be effected. What it had in mind was to discourage over-insurance.000.
1990] Post under case digests.640. 2. the cause of action on the policy accrues when the loss occurs. private respondent Lawrence Fernandez insured his car for "own damage" with petitioner Zenith Insurance Corporation. But when the policy provides that no action shall be brought unless the claim is first presented extrajudicially in the manner provided in the policy. Petitioner did not only object to the introduction of evidence but on the contrary. 2) other expenses incurred by the insured person by reason of such unreasonable denial or withholding of payment. it shall be the duty of the Commissioner or the Court. in case of unreasonable delay in the payment of the proceeds of an insurance policy. petitioner shifted upon private respondent the burden of fishing out the necessary information to ascertain the particular account of the articles destroyed by fire as well as the amount of loss.00 and litigation expenses of P3. Zenith filed an answer alleging that it offered to pay the claim of Fernandez pursuant to the terms and conditions of the contract which. and in the affirmative case. Petitioner further stressed that fraud which was not pleaded as a defense in private respondent's answer or motion to dismiss. It didn’t even furnish other documents. No. 3 and 11 of the contract. It appearing that insured has violated or failed to perform the conditions under No. and such violation or want of performance has not been waived by the insurer. from the date following the time prescribed in section two hundred forty-two or in section two hundred forty-three. Fernandez filed a complaint with the Regional Trial Court of Cebu for sum of money and damages resulting from the refusal of Zenith to pay the amount claimed. attorney's fees of P3. Generally. February 25. In case of any litigation for the enforcement of any policy or contract of insurance. 1986. to make a finding as to whether the payment of the claim of the insured has been unreasonably denied or withheld. 2012 Posted by Schizophrenic Mind Facts: On January 25.R. On September 28. It is clear that under the Insurance Code. 3) interest at twice the ceiling prescribed by the Monetary Board of the amount of the claim due the injured. which provides: Sec. Twenty-four days after the fire did petitioner merely wrote letters to private respondent to serve as a notice of loss. 11 specifically provides that the insured shall on the happening of any loss or damage give notice to the company and shall within fifteen (15) days after such loss or damage deliver to the private respondent (a) a claim in writing giving particular account as to the articles or goods destroyed and the amount of the loss or damage and (b) particulars of all other insurances. a decision was rendered by the trial court in favor of private respondent Fernandez. the Court of Appeals rendered its decision affirming in toto the decision of the trial court. 1983. if any. the damages that may be awarded are: 1) attorney's fees. 1983. until the claim is fully satisfied. 1983. it follows that private respondent could not be deemed to have finally rejected petitioner's claim and therefore there was no cause of action. On June 4. exemplary damages and attorney's fees is the main issue raised herein by petitioner. Provided. That the failure to pay any such claim within the time prescribed in said sections shall be considered prima facie evidence of unreasonable delay in payment. Fernandez also prayed for moral damages in the amount of P10. After allegedly being given a run around by Zenith for two (2) months. 85296 May 14. Commercial Law at Saturday. On July 6. together with the preliminary submittal of relevant documents had not been complied with. 244. and 4) the amount of the claim. it is but fair and just that where the insured who is primarily entitled to receive the proceeds of the policy has by its fraud and/or misrepresentation.000.000. CA [G. as the case may be. On August 17.00. exemplary damages of P5. Aside from actual damages and interests. the insured cannot recover. the insurance company shall be adjudged to pay damages which shall consist of attorney's fees and other expenses incurred by the insured person by reason of such unreasonable denial or withholding of payment plus interest of twice the ceiling prescribed by the Monetary Board of the amount ofthe claim due the insured. much less the herein petitioner. the car figured in an accident and suffered actual damages in the amount of P3. should be deemed to have been waived. the cause of action will accrue from the time the insurer finally rejects the claim for payment In the case at bar. Issue: The propriety of the award of moral damages.00. .000. as the case may be. policy condition No. 1988. Zenith Insurance Corporation vs.000. Held: The award of damages in case of unreasonable delay in thepayment of insurance claims is governed by the Philippine Insurance Code. presented the very evidence that proved its existence.Undoubtedly. forfeited said right. the private respondent rejected.00. Since the required claim by insured.00. Instead. It will be noted that the fact of fraud was tried by express or at least implied consent of the parties.
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