PHILIPPINE AMERICAN LIFE INSURANCE COMPANY vs. HON.

ARMANDO ANSALDO
G.R. No. 76543 | July 26, 1994
Topic: Office of the Insurance Commission. Admin and Adjudicatory Powers
Quiason, J.

FACTS:
 Private respondent Paterno wrote a letter-complaint to commissioner Ansaldo alleging
certain problems encountered by agents and consumers of Philamlife, particularly on the
illegality of the Contract of Agency (CoA).
 A hearing was held on the validity of the said CoA, wherein Paterno prayed that the
provisions on charges and fees stated in the CoA executed between Philamlife and its
agents, as well as the implementing provisions, be declared null and void.
o He also prayed to reimburse agents of the amounts deducted from charges and fees
already collected with interest.
 Philamlife contests that since the Insurance Commission’s quasi-judicial power was being
invoked, Paterno must first file a verified formal complaint before any further proceedings.
 Philamlife also filed a Motion to Quash Subpoena on the ground that the Commission has
no jurisdiction over the subject matter of the action and the parties involved. This Motion
was denied, hence this petition.

ISSUE: W/N the resolution of the illegality of the Contract of Agency falls within the
jurisdiction of the Insurance Commissioner

HELD: No, the Commissioner has no authority because the CoA entered into between
Philamlife and its agents is not included within the meaning of an insurance business
under Sec. 2(2) of the insurance Code. Expressio unius est exclusio alterius.

PETITION GRANTED. Order of Insurance Commissioner is SET ASIDE.

RATIO:
 Under Sec. 414 and 415 of the Insurance Code, the Commissioner has authority to regulate
the business of insurance, defined under Sec. 2(2). This “business” doesn’t include the CoA
entered into by Philamlife and its agents.
 Neither can the quasi-judicial power of the Commissioner under Sec. 416 be invoked.
o A reading of Sec. 416 shows that the quasi-judicial power of the Insurance
Commissioner is limited by law "to claims and complaints involving any loss, damage
or liability for which an insurer may be answerable under any kind of policy or contract
of insurance,…" Hence, this power does not cover the relation affecting the insurance
company and its agents but is limited to adjudicating claims and complaints filed
by the insured against the insurance company.
o The Insurance Code does not have provisions governing the relations between
insurance companies and their agents. While the topic of Insurance Agents and
Brokers are discussed in Chapter IV of the Code, the provisions only speak of
licensing requirements and limitations imposed on insurance agents and brokers.
o It follows that the Insurance Commissioner cannot, in the exercise of its quasi-judicial
powers, assume jurisdiction over controversies between the insurance companies and
their agents.
 Disputes involving insurance companies and agents, such as in this case, may be
cognizable by regular courts.