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59 Florendo vs. Philam Plans
59 Florendo vs. Philam Plans
59 Florendo vs. Philam Plans
FLORENDO vs. PHILAM PLANS life insurance, Philam Plans forwarded her claim to
GR 186983 | February 22, 2012 | Ponente Philam Life.
CONCEALMENT
On May 3, 1999 Philam Plans wrote Lourdes a letter,
Daming Sakit na pala si Father concealed lang!
declining her claim. Philam Life found that Manuel was
FACTS
on maintenance medicine for his heart and had an
Florendo filed an application for a pension plan implanted pacemaker. Further, he suffered from
with Philam Plans diabetes mellitus and was taking insulin.
The pension also provided life insurance coverage Whether or not the CA erred in finding that Philam
including accidental death, to all who signed up for Plans' approval of Manuel's pension plan application
Philam Plans' comprehensive pension plan and acceptance of his premium payments precluded it
from denying Lourdes' claim. (NO)
Aside from pension benefits, the comprehensive
pension plan also provided life insurance coverage to HELD:
Florendo. This was covered by a Group Master Policy
that Philippine American Life Insurance Company The wife argues that seeing the unfilled spaces in
(Philam Life) issued to Philam Plans. Under the master Manuel's pension plan application relating to his
policy, Philam Life was to automatically provide life medical history, Philam Plans should have returned
insurance coverage, including accidental death, to all it to him for completion.
who signed up for Philam Plans' comprehensive Since Philam Plans chose to approve the application
pension plan. If the plan holder died before the just as it was, it cannot cry concealment on Manuel's
maturity of the plan, his beneficiary was to instead part. Further, Lourdes adds that Philam Plans never
receive the proceeds of the life insurance, equivalent to queried Manuel directly regarding the state of his
the pre-need price. Further, the life insurance was to health. Consequently, it could not blame him for not
take care of any unpaid premium until the pension plan mentioning it.
matured, entitling the beneficiary to the maturity value
of the pension plan. Since Philam Plans waived medical examination for
Manuel, it had to rely largely on his stating the truth
Pension plan agreement was issued to Florendo regarding his health in his application.
with wife as beneficiary. Florendo died shortly after
But Lourdes is shifting to Philam Plans the burden of
On October 30, 1997 Philam Plans issued Pension Plan putting on the pension plan application the true state of
Agreement PP43005584 to Manuel, with petitioner Ma. Manuel's health. She forgets that since Philam Plans
Lourdes S. Florendo, his wife, as beneficiary. In time, waived medical examination for Manuel, it had to rely
Manuel paid his quarterly premiums. largely on his stating the truth regarding his health in
Lourdes files a claim under the plan. However, the his application. For, after all, he knew more than
claim was denied after it was discovered that the anyone that he had been under treatment for heart
husband had previously suffered from various condition and diabetes for more than five years
ailments. preceding his submission of that application. But he
kept those crucial facts from Philam Plans.
Eleven months later, Manuel died of blood poisoning.
Subsequently, Lourdes filed a claim with Philam Plans Clear from the representations that he concealed
for the payment of the benefits under her husband's his heart ailment and diabetes from Philam Plans.
plan. Because Manuel died before his pension plan Besides, when Manuel signed the pension plan
matured and his wife was to get only the benefits of his application, he adopted as his own the written