Cases:

1. Enriquez vs Sunlife assurance

Issue: W contract was perfected?

Held: No, Under the Civil code an acceptance made by letter shall not bind the person making the offer
except from the time it came to hos knowledge.

In the case at bar, it was not perfected because it has not been proved satisfactorily that the acceptance
of the application ever came to the knowledge of the applicant.

2. Heirs of Loreto vs De Guzman

Issue: W the illegitimate children are entitled as beneficiaries.

As provided under the insurance code of the Philippines that the insurance proceeds shall be applied
exclusively to the proper interest of the person in whose name or for whose benefit it is made, unless
otherwise specified in the policy.

The designation of illegitimate children as beneficiaries remains valid because no legal proscription
exists in naming as beneficiaries the children of elicit relationship by the insured. It is only the cases
where the insured has not designated any beneficiary, on when the designated beneficiary is
disqualified by the law to receive the proceeds, that the insurance policy proceeds shall redound to the
benefit of the estate of the insured.

3. Tongko vs Manulife

Issue:

4. Republic vs Del monte Motors

Republic vs Del Motors (G.R. No. 156956 October 9, 2006)

Republic of the Philippines vs Del Motors Inc.

G.R. No. 156956 October 9, 2006

Facts: On January 15, 2002, the RTC rendered a Decision in Civil Case No. Q-97-30412, finding the
defendants (Vilfran Liner, Inc., Hilaria Villegas and Maura Villegas) jointly and severally liable to pay Del
Monte Motors, Inc., P 11,835,375.50 representing the balance of Vilfran Liners service contracts with
respondent. The trial court further ordered the execution of the Decision against the counterbond
posted by Vilfran Liner on June 10, 1997, and issued by Capital Insurance and Surety Co., Inc.
(CISCO). On April 18, 2002, CISCO opposed the Motion for Execution filed by respondent, claiming that
the latter had no record or document regarding the alleged issuance of the counterbond; thus, the bond
was not valid and enforceable.

Issue: Whether or not the security deposit held by the Insurance Commissioner pursuant to Section 203
of the Insurance Code may be levied or garnished in favor of only one insured.

Held: No. Section 203 of the Insurance Code provides as follows:

Sec. 203. Every domestic insurance company shall, to the extent of an amount equal in value to twenty-
five per centum of the minimum paid-up capital required under section one hundred eighty-eight, invest
its funds only in securities, satisfactory to the Commissioner, consisting of bonds or other evidences of
debt of the Government of the Philippines or its political subdivisions or instrumentalities, or of
government-owned or controlled corporations and entities, including the Central Bank of the
Philippines: Provided, That such investments shall at all times be maintained free from any lien or
encumbrance; and Provided, further, That such securities shall be deposited with and held by the
Commissioner for the faithful performance by the depositing insurer of all its obligations under its
insurance contracts. The provisions of section one hundred ninety-two shall, so far as practicable, apply
to the securities deposited under this section.

Except as otherwise provided in this Code, no judgment creditor or other claimant shall have the right to
levy upon any of the securities of the insurer held on deposit pursuant to the requirement of the
Commissioner.

Basic is the statutory construction rule that provisions of a statute should be construed in accordance
with the purpose for which it was enacted. That is, the securities are held as a contingency fund to
answer for the claims against the insurance company by all its policy holders and their beneficiaries. This
step is taken in the event that the company becomes insolvent or otherwise unable to satisfy the claims
against it. Thus, a single claimant may not lay stake on the securities to the exclusion of all others. The
other parties may have their own claims against the insurance company under other insurance contracts
it has entered into.

The Insurance Code has vested the Office of the Insurance Commission with both regulatory and
adjudicatory authority over insurance matters. The general regulatory authority of the insurance
commissioner is described in Section 414 of the Code.

Pursuant to these regulatory powers, the commissioner is authorized to (1) issue (or to refuse to issue)
certificates of authority to persons or entities desiring to engage in insurance business in the Philippines;
(2) revoke or suspend these certificates of authority upon finding grounds for the revocation or
suspension; (3) impose upon insurance companies, their directors and/or officers and/or agents
appropriate penalties fines, suspension or removal from office for failing to comply with the Code
or with any of the commissioners orders, instructions, regulations or rulings, or for otherwise conducting
business in an unsafe or unsound manner.
As the officer vested with custody of the security deposit, the insurance commissioner is in the best position to
determine if and when it may be released without prejudicing the rights of other policy holders. Before allowing
the withdrawal or the release of the deposit, the commissioner must be satisfied that the conditions contemplated
by the law are met and all policy holders protected.

Section 192 specifically confers custody over the securities upon the Insurance Commissioner with whom
these investments are required to be deposited. An implied trust is created by law (see Arts. 1440,1441,
Civil Code.) for the benefit of all claimants under subsisting insurance contracts issued by the insurance
company. As the officer vested with the custody of the security deposit, the Commissioner is in the best
position to determine if and when it may be released without prejudicing the rights of policy holders.
(Republic vs. Del Monte Motors, Inc., 504 SCRA 53 [2006].)

Eternal Garden vs Philam Life

Issue: Wether Philam should pay eternal Garden?

Yes. As earlier stated, Philamlife and Eternal entered into an agreement denominated as Creditor Group
Life Policy No. P-1920 dated December 10, 1980. In the policy, it is provided that:

EFFECTIVE DATE OF BENEFIT.

The insurance of any eligible Lot Purchaser shall be effective on the date he contracts a loan with the
Assured. However, there shall be no insurance if the application of the Lot Purchaser is not approved by
the Company.

An examination of the above provision would show ambiguity between its two sentences. A
contract of insurance, being a contract of adhesion, par excellence, any ambiguity therein should be
resolved against the insurer. Moreover, the mere inaction of the insurer on the insurance application
must not work to prejudice the insured; it cannot be interpreted as a termination of the insurance
contract. The termination of the insurance contract by the insurer must be explicit and unambiguous.