Francisca Eguaras v. The Great Eastern Life Assurance Company

Summary

The Supreme Court reversed a lower court decision requiring an insurance company to pay a P5,000 life insurance claim. The case involved fraud in procuring the insurance policy when another person (Castor Garcia) was substituted for the actual insured (Dominador Albay) during the mandatory medical examination. Despite the beneficiary's acquittal in a related criminal estafa case, the Court found the insurance contract civilly void under Articles 1269-1270 of the Civil Code due to deceit. The fraud consisted of presenting a healthy person for examination while the real insured was ill with tuberculosis, thereby inducing the insurance company's consent through misrepresentation. The Court distinguished between criminal liability (estafa) and civil contract validity, holding that absence of criminal conviction did not prevent finding civil contract nullity due to proven fraud.