Case 14 Angelita Go v.

Ombudsman (adjudication of insurance claims) Administrative agency involved Insurance Commission Facts: Go filed separate insurance claims against 14 insurance agencies and sought the assistance of the Insurance Commission when she felt that her claims were unduly delayed. A conference was held by the Commission between Go and the insurance companies wherein they manifested their official stance to deny Gos claims. Go then filed with the Commission a complaint for the revocation or suspension of the insurance agencies licenses. Pending resolution of the administrative case, Go filed with the RTC a civil case for specific performance against the same parties. The Commission ordered the suspension of the administrative case because it is of the opinion that the determination by the Commission of the validity of the claims might conflict with that of the court, or vice-versa. Aggrieved, Go filed with the Office of the Ombudsman a complaint against Commissioner Malinis and Hearing Officer Castro of the Regulation Division for violation of Sec. 3 (e) of R.A. 3019. The Ombudsman, after conducting clarificatory hearings, dismissed the case on the ground that the conduct of separate hearings and issuance of the Order were all done in the regular performance of duties by the respondent Commission officers and that they were done in the purview of the rules of procedure governing the functions of the Insurance Commission. Issue: WoN the Commission committed with evident bad faith, manifest partiality or gross inexcusable negligence when it suspended the adjudication of Gos insurance claims. Held: The Office of the Insurance Commission is an administrative agency vested with regulatory power as well as with adjudicatory authority. Under its adjudicatory authority, the Commission has original jurisdiction to adjudicate and settle insurance claims and complaints where the amount being claimed does not exceed P100, 000 as provided in Sec. 416 0f the Insurance Code. In addition to its adjudicatory authority, the Commissioner has the regulatory authority to revoke or suspend the certificate or authority of an insurance company upon finding the legal grounds for such revocation or suspension under Secs. 241 and 247 of the Code. The jurisdiction of the Commission in the case filed by Go is one that calls for the exercise of its regulatory or non-quasi-judicial duty, to wit: the authority to revoke or suspend an insurers certificate of authority and the discretion to impose upon the erring insurance companies and its directors, officers and agents, fines and penalties, as set out in Sec. 415. The findings of the trial court will not necessarily foreclose the administrative case before the Commission, or vice-versa. While the possibility that these two bodies will come up with conflicting resolutions on the same issue is not far-fetched, the finding or conclusion of one would not necessarily be binding on the other given the difference in the issues involved, the quantum of evidence required and the procedure to be followed.

The suspension of the administrative case filed by Go although erroneous is not a sufficient indicia of evident bad faith, manifest partiality or gross inexcusable negligence. The officers mistaken sense of prudence and judgment, dictated the suspension of the proceedings and to hold them responsible for such error would be nothing short of harassment for no one called upon to try the facts or interpret the law in the process of administering justice can be infallible in his judgment.