No. L-26920 – CCC INSURANCE CORPORATION, petitioner, vs. COURT OF APPEALS (Fourth Division) and CARLOS F. ROBES, respondents.
REYES, J.B.L., J.
Rule Synopsis
For purposes of applying the authorized driver clauses customary in insurance policies, a driver’s license issued by the proper government agency is presumed genuine and valid; the burden of proof lies on the party who claims otherwise.
Facts
CCC Insurance Corporation refused to pay the claim for insurance proceeds of Carlos Robes under his accident policy with the former. The claim arose as his car covered by the insurance became involved in a collision while being driven by his driver. In denying the claim, the insurer claimed that there had been a violation of the insurance contract because the one driving the car at the time of the incident was not an “authorized driver.” The policy stated that the authorized driver is the following: 1) the insured; 2) [a]ny person driving on the insured’s order or with his permission, provided that the person driving is permitted by licensing laws or regulations to drive the motor vehicle… According to the insurer, as the driver does not know how to read and write, he could not have been able to secure the driver’s license which requires him to pass an examination.
The CFI ruled in favor of Robes. The CA affirmed. The SC affirmed.
Issue
Should CCC Insurance Corporation be held liable?
Ruling and Discussion
Yes. CCC Insurance Corporation should be held liable.
The Supreme Court held the insurer liable. It ruled that a driver’s license, regular upon its face, is a public instrument that is accorded the presumption of genuineness. The burden of proof to show otherwise lies with the party claiming its invalidity, in this case, the insurer. However, the latter failed to dispense such burden with the presentation of a mere certification by an agency of the Motor Vehicles Office that it did not issue the license in question. The latter may have been mistaken, or that the license may have been issued by another agency.
Dispositive
Decision affirmed.