insurance presentation 2
TRANSCRIPT
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G.R. No. 167330PHILIPPINE HEALTH CARE PROVIDERS,INC., Petitioner,
vs.
COMMISSIONER OF INTERNALREVENUE, Respondent.
G.R. No. 125678
PHILAMCARE HEALTH SYSTEMS, INC., Petitioner,vs.
COURT OF APPEALS and JULITA TRINOS, Respondents.
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This is based on a Motion for Reconsideration filed by the
petitioner.
Philippine Health Care Providers, Inc. is a domestic
corporation primarily engaged in the business of providing
prepaid group practice health care delivery system. On
January 27, 2000, the Commissioner of Internal Revenue sent
an assessment letter to the petitioner informing it and
demanding payment of P224, 702, 614. 18 in back taxes,
surcharge, and interests. The deficiency is composed mostly
of unpaid documentary stamp tax (DST) imposed on the
petitioners agreement with its members.
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Petitioner protested before the CIR but due to the latters
inaction; it filed a petition for review before the Court of Tax
Appeals. The CTA rendered a decision partially granting the
petition for review. The petitioner was ordered to pay P53M
instead of the original P225M. Furthermore, the CIR wasordered to desist from collecting DST tax
Respondent CIR appealed the decision before the Court
of Appeals. According to him, the petitioners healthcare
agreement is a contract of insurance and as such, is subjectto DST under Section 185 of the 1997 Tax Code. The CA
rendered a decision reversing the earlier decision of the CTA.
It ordered the petitioner to pay P123M in DST.
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Petitioner appealed the decision
before the Supreme Court whichaffirmed the CAs decision. The SC
held that the petitioners health care
agreement during the pertinent
period was in the nature of non-lifeinsurance which is a contract of
indemnity. The Court further ruled
that contracts between companies
like petitioner and its beneficiaries
under their plans are treated as
insurance contract. The petitioner
filed a motion for reconsideration.
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Whether or not the health care agreement
between petitioner and its beneficiaries is an
insurance contract.
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The Supreme Court ruled in favor of the petitioner andgranted the motion for reconsideration. The Court ruled thatthe health care agreement between the petitioners and itsbeneficiaries is not a contract of insurance.
The Court based its decision on the fact that the HMOagreement does not qualify as an insurance business basedon the principal object and purpose test. The test is basedon Section 2 (2) of the Insurance Code. Accordingly, anenterprise is considered engaged in an insurance business
when the principal object of the enterprise is the assumptionof risk and the indemnification of loss. If the enterpriseassumes risk and indemnifies beneficiaries for losses, then itis an insurance company.
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American courts have pointed out that the main differencebetween an HMO and an insurance company is that HMOsundertake to provide or arrange for the provision of medicalservices through participating physicians while insurancecompanies simply undertake to indemnify the insured for medicalexpenses incurred up to a pre-agreed limit.
A substantial portion of petitioners services covers preventive anddiagnostic medical services intended to keep members fromdeveloping medical conditions or diseases. As an HMO, it is itsobligation to maintain the good health of itsmembers. Accordingly, its health care programs are designed to
prevent or to minimize the possibility of any assumption of riskon its part. Thus, its undertaking under its agreements is not toindemnify its members against any loss or damage arising from amedical condition but, on the contrary, to provide the health andmedical services needed to prevent such loss or damage.
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Overall, petitioner appears to provide insurance-type benefits toits members (with respect to its curative medical services), butthese are incidental to the principal activity of providing themmedical care. The insurance-like aspect of petitioners businessis miniscule compared to its non-insurance activities. Therefore,since it substantially provides health care services rather thaninsurance services, it cannot be considered as being in theinsurance business.
Lastly, it is significant that petitioner, as an HMO, is not part ofthe insurance industry. This is evident from the fact that it is notsupervised by the Insurance Commission but by the Department ofHealth. In fact, in a letter dated September 3, 2000, the Insurance
Commissioner confirmed that petitioner is not engaged in theinsurance business. This determination of the commissioner mustbe accorded great weight. It is well-settled that the interpretation ofan administrative agency which is tasked to implement a statute isaccorded great respect and ordinarily controls the interpretation oflaws by the courts.
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HEALTH MAINTENANCE ORGANIZATIONS ARENOT ENGAGED IN THE INSURANCE BUSINESS
From the language of Section 185, it is evident that two requisites must
concur before the DST can apply, namely: (1) the document must be a
policy of insurance or an obligation in the nature of indemnity and (2) themaker should be transacting the business of accident, fidelity, employers
liability, plate, glass, steam boiler, burglar, elevator, automatic sprinkler, or
other branch of insurance (except life, marine, inland, and fire insurance).
Petitioner is admittedly an HMO. Under RA 7875 (or The National
Health Insurance Act of 1995), an HMO is an entity that provides, offers orarranges for coverage of designated health services needed by plan members for a fixed
prepaid premium.The payments do not vary with the extent, frequency or
type of services provided.
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PRINCIPAL OBJECT AND PURPOSE TEST
Various courts in the United States, whose jurisprudence has a persuasive
effect on our decisions, have determined that HMOs are not in the
insurance business. One test that they have applied is whether theassumption of risk and indemnification of loss (which are elements of an
insurance business) are the principal object and purpose of the
organization or whether they are merely incidental to its business. If these
are the principal objectives, the business is that of insurance. But if they
are merely incidental and service is the principal purpose, then the
business is not insurance.
Applying the principal object and purpose test, there is significantAmerican case law supporting the argument that a corporation (such as an
HMO, whether or not organized for profit), whose main object is to
provide the members of a group with health services, is not engaged in
the insurance business.
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A HEALTH CARE AGREEMENT IS NOT AN
INSURANCE CONTRACT CONTEMPLATED
UNDER SECTION 185 OF THE NIRC OF 1997
Section 185. Stamp tax on fidelity bonds and other insurance policies . On all
policies of insurance or bonds or obligations of the nature of
indemnity for loss, damage, or liability made or renewed by anyperson, association or company or corporation transacting the business
of accident, fidelity, employers liability, plate, glass, steam boiler,
burglar, elevator, automatic sprinkler, or other branch of insurance
(except life, marine, inland, and fire insurance)
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First. In our jurisdiction, a commentator of our insurance laws has pointed out
that, even if a contract contains all the elements of an insurance contract, if its
primary purpose is the rendering of service, it is not a contract of insurance:
The primary purpose of the parties in making the contract may negate the existence of an
insurance contract
Second. Not all the necessary elements of a contract of insurance are present in
petitioners agreements. To begin with, there is no loss, damage or liability on
the part of the member that should be indemnified by petitioner as an
HMO. Under the agreement, the member pays petitioner a predetermined
consideration in exchange for the hospital, medical and professional services
rendered by the petitioners physician or affiliated physician to him. In case of
availment by a member of the benefits under the agreement, petitioner does notreimburse or indemnify the member as the latter does not pay any third
party. Instead, it is the petitioner who pays the participating physicians and
other health care providers for the services rendered at pre-agreed rates. The
member does not make any such payment.
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Third. According to the agreement, a member can take advantage of the bulk
of the benefits anytime, e.g. laboratory services, x-ray, routine annual physicalexamination and consultations, vaccine administration as well as family
planning counseling, even in the absence of any peril, loss or damage on his
or her part.
Fourth. In case of emergency, petitioner is obliged to reimburse the member
who receives care from a non-participating physician or hospital. However,this is only a very minor part of the list of services available. The
assumption of the expense by petitioner is not confined to the happening of
a contingency but includes incidents even in the absence of illness or injury.
Fifth. Although risk is a primary element of an insurance contract, it is not
necessarily true that risk alone is sufficient to establish it. Almost anyone
who undertakes a contractual obligation always bears a certain degree of
financial risk. Consequently, there is a need to distinguish prepaid service
contracts (like those of petitioner) from the usual insurance contracts.
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In the application of the provisions of this Code, the fact thatIn the application of the provisions of this Code, the fact thatno profit is derived from the making of insurance contracts,no profit is derived from the making of insurance contracts,
agreements or transactions or that no separate or directagreements or transactions or that no separate or direct
consideration is received therefore, shall not be deemedconsideration is received therefore, shall not be deemed
conclusiveconclusive to show that the making thereof does notto show that the making thereof does not
constitute the doing or transacting of an insurance business.constitute the doing or transacting of an insurance business.
Section 2 (2) of PD 1460Section 2 (2) of PD 1460 (otherwise known as the Insurance Code) enumerates(otherwise known as the Insurance Code) enumerateswhat constitutes doing an insurance business or transacting an insurancewhat constitutes doing an insurance business or transacting an insurance
business:business:
a) making or proposing to make, as insurer, any insurancea) making or proposing to make, as insurer, any insurance contract;contract;
b)b) making or proposing to make, as surety, any contract of suretyship as a vocationmaking or proposing to make, as surety, any contract of suretyship as a vocation
and not as merely incidental to any other legitimate business or activity of theand not as merely incidental to any other legitimate business or activity of the
surety;surety;
c)c) doing any kind of business, including a reinsurance business, specificallydoing any kind of business, including a reinsurance business, specificallyrecognized as constituting the doing of an insurance business within the meaningrecognized as constituting the doing of an insurance business within the meaning
of this Code;of this Code;
d)d) doing or proposing to do any business in substance equivalent to any of thedoing or proposing to do any business in substance equivalent to any of the
foregoing in a manner designed to evade the provisions of this Code.foregoing in a manner designed to evade the provisions of this Code.
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THERE WAS NO LEGISLATIVE INTENT
TO IMPOSE DST ON HEALTH CARE
AGREEMENTS OF HMOS
Section 116, Article XI of Act No. 1189 (otherwise known as the Internal
Revenue Law of 1904) enacted on July 2, 1904 and became effective on
August 1, 1904
On February 27, 1914, Act No. 2339 (the Internal Revenue Law of 1914) was
enacted revising and consolidating the laws relating to internal revenue
On December 31, 1916, Section 30 (l), Article III of Act No. 2339 was again
reproduced as Section 1604 (l), Article IV of Act No. 2657 (Administrative
Code)
Its amendment on March 10, 1917, the pertinent DST provision became
Section 1449 (l) of Act No. 2711, otherwise known as the Administrative Code
of 1917
History of Documentary Stamp Tax
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Section 1449 (1) eventually became Sec. 222 of Commonwealth Act No. 466(the NIRC of 1939), which codified all the internal revenue laws of the
Philippines
On June 3, 1977, the same provision with the same DST rate was reproduced
in PD 1158 (NIRC of 1977) as Section 234
Effective January 1, 1986, pursuant to Section 45 of PD 1994, Section 234 of
the NIRC of 1977 was renumbered as Section 198. And under Section 23 of
EO 273 dated July 25, 1987, it was again renumbered and became Section 185
On December 23, 1993, under RA 7660, Section 185 was amended but, again,
only with respect to the rate of tax
In 2004, amendments to the DST provisions were introduced by RA 9243 but
Section 185 was untouched.
History of Documentary Stamp Tax
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The concept of an HMO was introduced in the Philippines with the
formation of Bancom Health Care Corporation in 1974. The same pioneerHMO was later reorganized and renamed Integrated Health Care Services,
Inc. (or Intercare). However, there are those who claim that Health
Maintenance, Inc. is the HMO industry pioneer, having set foot in the
Philippines as early as 1965 and having been formally incorporated in 1991.
Afterwards, HMOs proliferated quickly and currently, there are 36 registeredHMOs with a total enrollment of more than 2 million.
History of Health MaintenanceOrganizations (HMOs)
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NoteNoteWe can clearly see from these two histories (of the DST on the one hand
and HMOs on the other) that when the law imposing the DST was first
passed, HMOs were yet unknown in the Philippines. However, when the
various amendments to the DST law were enacted, they were already in
existence in the Philippines and the term had in fact already been defined
by RA 7875. If it had been the intent of the legislature to impose DST onhealth care agreements, it could have done so in clear and categorical
terms. It had many opportunities to do so. But it did not. The fact that
the NIRC contained no specific provision on the DST liability of
health care agreements of HMOs at a time they were already known
as such, belies any legislative intent to impose it on them. As a matterof fact, petitioner was assessed its DST liability only on January 27, 2000,
after more than a decade in the business as an HMO.
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THE POWER TO TAX IS NOTTHE POWER TO DESTROY
As a general rule, the power to tax is an incident of sovereignty and isunlimited in its range, acknowledging in its very nature no limits, so that
security against its abuse is to be found only in the responsibility of thelegislature which imposes the tax on the constituency who is to pay it. So
potent indeed is the power that it was once opined that the power to tax
involves the power to destroy.
Petitioner claims that the assessed DST to date which amounts to P376
million is way beyond its net worth of P259 million. Respondent neverdisputed these assertions. Given the realities on the ground, imposing the
DST on petitioner would be highly oppressive. It is not the purpose of the
government to throttle private business.
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On the contrary, the government ought to encourage private enterprise.
Petitioner, just like any concern organized for a lawful economic activity,has a right to maintain a legitimate business. As aptly held in Roxas, et al. v.
CTA, et al.:
The power of taxation is sometimes called also the power to destroy. Therefore it should
be exercised with caution to minimize injury to the proprietary rights of a taxpayer. It must beexercised fairly, equally and uniformly, lest the tax collector kill the hen that lays the golden
egg.
Legitimate enterprises enjoy the constitutional protection not to be taxed
out of existence. Incurring losses because of a tax imposition may be an
acceptable consequence but killing the business of an entity is anothermatter and should not be allowed. It is counter-productive and ultimately
subversive of the nations thrust towards a better economy which will
ultimately benefit the majority of our people.
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PETITIONERS TAX LIABILITYWAS EXTINGUISHED UNDER THE
PROVISIONS OF RA 9840
Petitioner asserts that, regardless of the arguments, the DST assessment for
taxable years 1996 and 1997 became moot and academic when it availed of the
tax amnesty under RA 9480 on December 10, 2007. It paid
P5,127,149.08 representing 5% of its net worth as of the year endedDecember 31, 2005 and complied with all requirements of the tax
amnesty. Under Section 6(a) of RA 9480, it is entitled to immunity from
payment of taxes as well as additions thereto, and the appurtenant civil,
criminal or administrative penalties under the 1997 NIRC, as amended,
arising from the failure to pay any and all internal revenue taxes for taxable
year 2005 and prior years.
Furthermore, we held in a recent case that DST is one of the taxes covered by
the tax amnesty program under RA 9480. There is no other conclusion to
draw than that petitioners liability for DST for the taxable years 1996 and 1997
was totally extinguished by its availment of the tax amnesty under RA 9480.
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Ernani Trinos, deceased husband of respondent JulitaErnani Trinos, deceased husband of respondent Julita
Trinos, applied for a health care coverage with petitionerTrinos, applied for a health care coverage with petitioner
Philamcare Health Systems, Inc. In the standard applicationPhilamcare Health Systems, Inc. In the standard application
form, he answered no to the following question:form, he answered no to the following question:
Have you or any of your family members everHave you or any of your family members ever
consulted or been treated for high blood pressure, heartconsulted or been treated for high blood pressure, heart
trouble, diabetes, cancer, liver disease, asthma or peptictrouble, diabetes, cancer, liver disease, asthma or pepticulcer? (If Yes, give details).ulcer? (If Yes, give details).
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The application was approved for a period of one year fromThe application was approved for a period of one year from
March 1, 1988 to March 1, 1989. Accordingly, he was issued HealthMarch 1, 1988 to March 1, 1989. Accordingly, he was issued HealthCare Agreement No. P010194. Under the agreement, respondentsCare Agreement No. P010194. Under the agreement, respondents
husband was entitled to avail of hospitalization benefits, whetherhusband was entitled to avail of hospitalization benefits, whether
ordinary or emergency, listed therein. He was also entitled to availordinary or emergency, listed therein. He was also entitled to avail
of "outof "out--patient benefits" such as annual physical examinations,patient benefits" such as annual physical examinations,preventive health care and other outpreventive health care and other out--patient services.patient services.
Upon the termination of the agreement, theUpon the termination of the agreement, the
same was extended for another year fromsame was extended for another year from
March 1, 1989 to March 1, 1990, then fromMarch 1, 1989 to March 1, 1990, then fromMarch 1, 1990 to June 1, 1990. The amount ofMarch 1, 1990 to June 1, 1990. The amount of
coverage was increased to a maximum sum ofcoverage was increased to a maximum sum of
P75,000.00 per disability.P75,000.00 per disability.
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After her husband was discharged from the MMC, he wasattended by a physical therapist at home. Later, he was admitted
at the Chinese General Hospital. Due to financial difficulties,
however, respondent brought her husband home again. In the
morning of April 13, 1990, Ernani had fever and was feeling very
weak. Respondent was constrained to bring him back to theChinese General Hospital where he died on the same day.
On July 24, 1990, respondent instituted with the Regional Trial
Court of Manila, Branch 44, an action for damages against
petitioner and its president, Dr. Benito Reverente, which wasdocketed as Civil Case No. 90-53795. She asked for
reimbursement of her expenses plus moral damages and
attorneys fees. After trial, the lower court ruled against
petitioners.
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On appeal, the Court of Appeals affirmed the decision of the
trial court but deleted all awards for damages and absolved
petitioner Reverente. Petitioners motion for reconsideration
was denied. Hence, petitioner brought the instant petition forreview, raising the primary argument that a health care
agreement is not an insurance contract; hence the
"incontestability clause" under the Insurance Code does not
apply.
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Whether or not a healthcare agreement is
not an insurance contract.Whether or not the petitioner is liable
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The Supreme Court ruled that there is a valid insurancecontract, after all, all the elements for an insurance contractare contract are present and alleged concealment answersmade in good faith and without intent to deceive will not
avoid the policy. The insurer, in case of material fact, is notjustified in relying upon such statement, but obligated tomake further inquiry.
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Yes. The health care agreement was in the nature of non-lifeinsurance, which is primarily a contract of indemnity. Once themember incurs hospital, medical or any other expense arisingfrom sickness, injury or other stipulated contingent, the healthcare provider must pay for the same to the extent agreed uponunder the contract.
Petitioner alleges that respondent was not the legal wife of thedeceased member considering that at the time of their marriage,the deceased was previously married to another woman who wasstill alive. The health care agreement is in the nature of a contractof indemnity. Hence, payment should be made to the party who
incurred the expenses. It is not controverted that respondent paidall the hospital and medical expenses. She is therefore entitled toreimbursement. The records adequately prove the expensesincurred by respondent for the deceaseds hospitalization,medication and the professional fees of the attending physicians.
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CONTRACT OF INSURANCE IS
A CONTRACT OF INDEMNITY
1. The insured has an insurable interest;
2. The insured is subject to a risk of loss by the happening of the
designated peril;
3. The insurer assumes the risk;
4. Such assumption of risk is part of a general scheme to distribute actual
losses among a large group of persons bearing a similar risk; and
5. In consideration of the insurers promise, the insured pays a premium.
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The Court pronounced that a health careagreement is in the nature of non-life
insurance, which is primarily a contract of
indemnity. However, those cases did not
involve the interpretation of a taxprovision. Instead, they dealt with the
liability of a health service provider to a
member under the terms of their health care
agreement. Such contracts, as contracts of
adhesion, are liberally interpreted in favor of
the member and strictly against the HMO.
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SECTION 10 OF THE INSURANCE
CODE
(1) of himself, of his spouse and of his children;
(2) of any person on whom he depends wholly or in part for education or
support, or in whom he has a pecuniary interest;
(3) of any person under a legal obligation to him for the payment of money,
respecting property or service, of which death or illness might delay orprevent the performance; and
(4) of any person upon whose life any estate or interest vested in him depends.
In the case at bar, the insurable interest of respondents husband in obtaining
the health care agreement was his own health. The health care agreement wasin the nature of non-life insurance, which is primarily a contract of
indemnity.9 Once the member incurs hospital, medical or any other expense
arising from sickness, injury or other stipulated contingent, the health care
provider must pay for the same to the extent agreed upon under the contract.
Every person has an insurable interest in the life and health:
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SECTION 27 OF THE INSURANCE CODE
The cancellation of health care agreements as in insurance policies require the
concurrence of the following conditions:
Prior notice of cancellation to insured;
Notice must be based on the occurrence after effective date of the policy of
one or more of the grounds mentioned;
Must be in writing, mailed or delivered to the insured at the address shown inthe policy;
Must state the grounds relied upon provided in Section 64 of the Insurance
Code and upon request of insured, to furnish facts on which cancellation is
based.
"a concealment entitles the injured party to rescind a contract of insurance."The right to rescind shouldbe exercised previous to the commencement of an action on the contract.
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Petitioner cannot rely on the stipulation regarding "Invalidation of agreement"
which reads:
Failure to disclose or misrepresentation of any material information by the member in the application or medical
examination, whether intentional or unintentional, shall automatically invalidate theAgreement from the very
beginning and liability of Philamcare shall be limited
Petitioner argues that respondents husband concealed a material fact in his application. It appears that in
the application for health coverage, petitioners required respondents husband to sign an express
authorization for any person, organization or entity that has any record or knowledge of his health to
furnish any and all information relative to any hospitalization, consultation, treatment or any other
medical advice or examination.1
The answer assailed by petitioner was in response to the question relating to the medical history of the
applicant. This largely depends on opinion rather than fact, especially coming from respondents husband
who was not a medical doctor. Where matters of opinion or judgment are called for, answers madeWhere matters of opinion or judgment are called for, answers made
in good faith and without intent to deceive will not avoid a policy even though they are untrue.in good faith and without intent to deceive will not avoid a policy even though they are untrue.
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Incontestability Clause
Clause in life insurance policy that stipulates that the
policy shall be incontestable after a stated period.
Requisites:
Life insurance policy
Payable on the death of the insured
It has been in force during the lifetime of the insuredfor a period of at least two years from the date of its
issue or of its last reinstatement
INCONTESTABILITY CLAUSE: APPLICABILITY
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On appeal, the Court of Appeals affirmed the decision of the trial court butdeleted all awards for damages and absolved petitioner Reverente. Petitioners
motion for reconsideration was denied. Hence, petitioner brought the instant
petition for review, raising the primary argument that a health care agreement
is not an insurance contract; hence the "incontestability clause" under the
Insurance Code does not apply.
Anent the incontestability of the membership of respondents husband, we quote
with approval the following findings of the trial court:
(U)nder the title Claim procedures of expenses, the defendant Philamcare Health
Systems Inc. had twelve months from the date of issuance of the Agreement
within which to contest the membership of the patient if he had previous
ailment of asthma, and six months from the issuance of the agreement if the
patient was sick of diabetes or hypertension. The periods having expired, the
defense of concealment or misrepresentation no longer lie.
INCONTESTABILITY CLAUSE: APPLICABILITY
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THETHE
ENDEND