Industrial Personnel v. Country Bankers Insurance Corporation

Summary

IPAMS recruited nurses for US deployment, requiring surety bonds from Country Bankers to guarantee completion of immigration processes. Their MOA specified claim requirements: demand letters, affidavits, and statements of accounts. Country Bankers initially paid claims but stopped in 2004, demanding official receipts despite MOA terms. The Supreme Court ruled that parties validly stipulated alternative documentation requirements under Civil Code Article 2199's exception provision. Country Bankers waived its right to require official receipts through prior conduct of accepting similar claims without such receipts. The Court applied Insurance Code Section 92, finding defects in proof of loss waived when insurer fails to specify them promptly. Administrative agencies' findings that Country Bankers committed unfair claim settlement practices were reinstated, though the case was remanded to determine remaining liability amounts.