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Malayan v. Stronghold (Insurance)

The document summarizes an insurance dispute between Malayan Insurance and Stronghold Insurance regarding claims from an accident involving Pablo's vehicle. Stronghold, as Pablo's primary insurer, argued its liability was limited by the schedule of indemnities in its policy. However, the court ruled the schedule sets maximum payouts for specific injury types but does not restrict other valid claims. It was not an exhaustive list. Therefore, Stronghold was liable for the full amount of its coverage, with Malayan liable for excess claims. This interpretation upheld the purpose of limiting specific injury payouts in the schedule without excluding other covered damages.

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256 views1 page

Malayan v. Stronghold (Insurance)

The document summarizes an insurance dispute between Malayan Insurance and Stronghold Insurance regarding claims from an accident involving Pablo's vehicle. Stronghold, as Pablo's primary insurer, argued its liability was limited by the schedule of indemnities in its policy. However, the court ruled the schedule sets maximum payouts for specific injury types but does not restrict other valid claims. It was not an exhaustive list. Therefore, Stronghold was liable for the full amount of its coverage, with Malayan liable for excess claims. This interpretation upheld the purpose of limiting specific injury payouts in the schedule without excluding other covered damages.

Uploaded by

johnllenalcantara
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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TOLENTINO, RAPHAEL JOSHUA A.

2BB - 2017096681
INTRO TO COMMERCIAL LAW

MALAYAN INSURANCE COMPANY, INC. vs. STRONGHOLD INSURANCE COMPANY, INC.

G.R. No. 203060, June 28, 2021

Facts:

1) Pablo obtained a Compulsory Third-Party Liability (CTPL) insurance for his vehicle from Stronghold
with a limit of PI00,000.00, which contained a schedule of indemni�es. Insurance Memorandum
Circular No. 4-200611 (IMC No. 4-2006) is the most recent issuance at that �me that sets the limits
of third-party liability and indemni�es in setlement of claims under compulsory motor vehicle
liability insurance (CMVLI) policies.
2) Pablo also obtained an Excess Cover for Third Party Bodily and Death Liability from Malayan for
the same vehicle. The amount of the excess coverage is P200,000.00.
3) During the effec�vity of the two policies, Pablo, while driving the insured vehicle, sideswiped a
pedestrian who sustained injuries and was brought to the hospital for treatment. Pablo claimed
that he incurred hospital and medical expenses in the amount of PI00,318.08 for the treatment of
the pedestrian. As a result, he filed third party liability claims for reimbursement with both
Stronghold and Malayan.
4) Stronghold computed its liability based on the schedule of indemni�es provided in the CTPL
insurance policy and arrived at the amount of P29,000.00. The excess of P71,318.08 was not
covered or in excess of the limits in the schedule of indemni�es and should be shouldered by
Malayan.
5) Pablo sought the assistance of the IC through a leter.
6) IC Ruling: Stronghold should pay Pablo the amount of P 1 00K, and Malayan should pay Pablo the
remaining amount of P318.08. Stronghold appealed to the CA.
7) CA Ruling: Stronghold should pay Pablo P42,714.83; Malayan should pay Pablo P57,603.25.

Issue: W/N Stronghold is correct in in their claim of the limits of their liability pursuant to the insurance
policy it issued

Ruling: No.

The Schedule of Indemni�es does not purport to restrict the kinds of damages that may be awarded
against the insurance company once liability has arisen, and the requisites for each kind of damages are
present. The schedule is not an enumera�on of the specific kinds of damages that may be awarded. It was
merely meant to set limits to the amounts the movant would be liable for in cases of death, bodily injuries
of, professional services rendered to traffic accident vic�ms, and not necessarily exclude claims against
the insurance policy for other kinds of damages.

The limit of liability with regard to the items listed in the Schedule of Indemni�es is the amount provided
therein; the limit of liability with regard to other kinds of damages not listed in the same Schedule of
Indemni�es is the total amount of insurance coverage. It then follows that the amounts in excess of the
limits of liability in the schedule for items listed therein are not covered by the total coverage. Such
excess is already for the personal account of the insured or an excess coverage provider. This
interpreta�on upholds the purpose of indica�ng limits of liability on the specific injuries listed in the
schedule.

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