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PHILIPPINE AMERICAN INSURANCE COMPANY v CA [344 SCRA 620 (November 15, 2000)]

Nature: Petition for review on certiorari of a decision of the CA.


Ponente: J. Gonzaga-Reyes

Facts:
January 9: 1989: Phil-Am received from Florence Pulido an application for life insurance policy
with a face value of P100,000 and naming her sister, Eliza Pulido as beneficiary.
Feb. 11, 1989: Phil-Am issued a life insurance policy on the sole basis of the application since it
was a non-medical insurance (did not require medical examination)
April 1992: Eliza filed a claim with Phil-Am saying that Florence died of acute pneumonia on
September 10, 1991.
Phil-Am withheld payment saying that the policy was null and void from the beginning since
Florence (according to their investigations) was already dead at the time the application for the
policy was submitted to them.
3 Investigations by Phil-Am:
o 1st: by Dr. Briones with an attached questionnaire answered by Ramaon Piganto,
brother-in-law of Florence; in the said questionnaire Ramon said that Florence was dead
sonce 1988 Ramon contested this at trial saying he was made to sign a blank coupon
bond; Dr. Briones was never called on to testify BASED on this Angalato (Phil-Ams
Life Claims Manager) said that even before Eliza filed her claim, the Claims Committee
had already declared the policy null and void.
o 2nd: by Ferdinand Tanchoco saying he interviewed Remylyn, Ramons daughter and
Florences 14 year old niece saying that her aunt died even before she was born
although at trial Tanchoco testitfied that Elizas information as to the death of Florence
was consistent with the one in the entries of the death certificate found in the Local Civil
Register of La Union
o 3rd: by Dr. Briones again saying that neighbors (who refused to give names and testify)
claim that Florence died in 1985 again Dr. Briones was not called to testify during trial
Elizas evidence:
o Testimony by Dr. Gutierrez, the Municipal Health officer that he issued a death
certificate saying that Florence did indeed die of acute pneumonia on September 10,
1991 at around 4pm, and saying that he treated her on September 8 and 9 (also shown
in the death certificate)
o Villano: neighbor who testified that he was there when Dr. Gutierrez attended to
Florence and also during the latters wake.
RTC: Eliza can claim on policy the face value of P100,000
o Correctness of entries in the Certificate of Death
o Phil-Am failed to prove fraud
Only hearsay evidence as to the reports of Dr. Briones
Testimony of Remylyn recounted by Tanchoco also hearsay
o No legal interest because there was no unreasonable delay in Phil-Ams decision to
withhold since they based it on an alleged fraud.
CA affirmed in toto

Issue: WON the Death certificate was valid proof of loss.

Held/Ratio:
YES.
The question of fraud is a legal question that the SC did not pass upon; it declared that the findings of
the TC are binding and no need to disturb them.
Death certificates, and notes by a municipal health officer prepared in the regular performance of his
duties, are prima facie evidence of facts therein stated. A duly-registered death certificate is
considered a public document and the entries found therein are presumed correct, unless the party
who contests its accuracy can produce positive evidence establishing otherwise.

Phil-Ams contention that the death certificate is suspect because Dr. Gutierrez was not present when
Florence died, and knew of Florences death only through Ramon Piganto, does not merit a conclusion
of fraud. No motive was imputed to Dr. Gutierrez for seeking to perpetuate a falsity in public records.

Phil-Am was likewise unable to make out any clear motive as to why Ramon Piganto would purposely
lie. Mere allegations of fraud could not substitute for the full and convincing evidence that is required
to prove it. A failure to do so would leave intact the presumption of good faith and regularity in the
performance of public duties, which was the basis of both respondent court and the trial court in
finding the date of Florences death to be as Eliza maintained.

Disposition: Petition denied.