- Petitioner
- Land Bank of the Philippines
- Respondent
- Maria Josefina G. Miranda
- Citation
- G.R. No. 220706
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Gaerlan, J.
- Decided
- February 22, 2023
Summary
This consolidated case involves a dispute over a Mortgage Redemption Insurance (MRI) in connection with a P2.4 million loan obtained by Miranda and co-borrowers from LBP in 1998. When co-borrower Robert Glenn Fox died, Miranda believed their loan was covered by MRI and stopped payments. LBP foreclosed the mortgage, prompting Miranda to file suit claiming the MRI extinguished their obligation. The Supreme Court affirmed lower courts' findings that no MRI contract was perfected due to Miranda's failure to submit the application and LIBI's policy of not covering business loans. However, the Court held LBP liable for damages under Civil Code Articles 1897 and 19-21 for acting as insurance agent beyond its authority, knowing the MRI was inapplicable but still collecting premiums and making representations that deceived Miranda. The Court awarded moral damages, reimbursement of premium, attorney's fees, and costs, emphasizing that agents who exceed authority without disclosure are liable for resulting damages.