Summit Guaranty & Insurance v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Certeza & Sons, Inc. insured a Toyota Jeep with Summit Guaranty & Insurance Company, Inc. under a comprehensive policy for third-party liability. On August 20, 1977, the insured vehicle was involved in an accident resulting in the death of a passenger, George Certeza, injuries to a pedestrian, and injuries to passengers in another vehicle. The insured, Leonardo Certeza, settled the medical and hospitalization expenses. Subsequently, a demand for payment of P20,000.00 for the death of George Certeza was made upon the insurance company. 2. Procedural History: Following the insurance company's failure to pay, a complaint was filed with the Insurance Commission, which rendered a judgment against Summit Guaranty & Insurance Company, Inc. ordering them to pay P20,000.00 plus interest and attorney's fees. The petitioner appealed this decision to the Court of Appeals. The Court of Appeals dismissed the petition for review and denied the subsequent motion for reconsideration. This led to the filing of the present recourse. 3. The Petition: The petitioner seeks a writ of certiorari, prohibition, and mandamus to annul the orders of the Court of Appeals and to restrain the Insurance Commissioner from proceeding further. The petitioner argues that the Court of Appeals lacked jurisdiction to hear the appeal, as Presidential Decree No. 1455 transferred appellate jurisdiction from the Insurance Commissioner directly to the Supreme Court. The petitioner also contends that the Insurance Commissioner erred in ordering payment of the policy value.
Issue(s)
Whether the Court of Appeals had appellate jurisdiction over decisions of the Insurance Commissioner. Whether the petitioner is estopped from questioning the jurisdiction of the Court of Appeals. Whether the petitioner is exempt from liability under the insurance policy.
Ruling
The petition is denied. The judgment of the Insurance Commission is affirmed. The temporary restraining order is lifted and set aside.
Ratio Decidendi
On the jurisdiction of the Court of Appeals: The Court held that Section 416 of the Insurance Code, as amended by Presidential Decree No. 1455, which took effect on June 11, 1978, vests appellate jurisdiction over decisions of the Insurance Commissioner exclusively in the Supreme Court. Therefore, the Court of Appeals indeed lacked appellate jurisdiction over the decision rendered on February 2, 1979. On estoppel to question jurisdiction: Despite the lack of jurisdiction of the Court of Appeals, the Court ruled that the petitioner is estopped from raising this issue. The petitioner voluntarily submitted to the jurisdiction of the Court of Appeals by filing a notice of appeal, seeking an extension of time to file its petition for review, and filing the petition itself without questioning the appellate court's jurisdiction. It was only after an adverse decision that the petitioner belatedly raised the issue of jurisdiction. The Court cited the principle that a party cannot invoke the jurisdiction of a court to secure affirmative relief and then repudiate that same jurisdiction after an adverse decision, emphasizing that this is based on public policy and the doctrine of laches. On exemption from liability: The Court found the petitioner's defense of exemption from liability to be without merit. The policy's excepted risk provision covered death or injury to an employee of the insured arising out of employment, or death or injury to a member of the insured's household who is a passenger. There was no evidence that the deceased, George Certeza, was an employee of Certeza & Sons, Inc. Furthermore, the Court clarified that a corporation has a personality separate from its officers, and thus, George Certeza, as the son of an officer (Leonardo Certeza), could not be considered a member of the household of the insured corporation. The burden of proof for affirmative allegations, such as the deceased being an employee, rests on the party asserting it, which was the petitioner in this instance.
Main Doctrine
A party who voluntarily submits to the jurisdiction of a court and participates in the proceedings until an adverse decision is rendered is estopped from questioning the court's jurisdiction.