Benchoff v. Paradise Mutual Insurance

14 Pa. D. & C.2d 763, 1958 Pa. Dist. & Cnty. Dec. LEXIS 410
CourtPennsylvania Court of Common Pleas, Adams County
DecidedMarch 10, 1958
Docketno. 6
StatusPublished

This text of 14 Pa. D. & C.2d 763 (Benchoff v. Paradise Mutual Insurance) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Adams County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Benchoff v. Paradise Mutual Insurance, 14 Pa. D. & C.2d 763, 1958 Pa. Dist. & Cnty. Dec. LEXIS 410 (Pa. Super. Ct. 1958).

Opinion

Sheely, P. J.,

This is a motion by plaintiff to take off a compulsory nonsuit entered after the introduction of a portion of plaintiff’s testimony at the trial.

The action is based upon policies of insurance issued by defendant companies insuring plaintiff against loss by windstorm, etc. Each of the policies contained a clause to the effect that “this entire policy shall be void ... if the interest of the insured be other than unconditional and' sole ownership.” The testimony of plaintiff indicated that he purchased the insured premises from his parents, H. N. Benchoff and Lottie Benchoff, by deed dated March 22, 1945, which deed contained the provision: “The grantors except and reserve unto themselves the use and occupation of the premises herein conveyed for and during the term of their natural life or the survivor of them.”

We think it is clear that the reservation to the grantors in the deed of the “use and occupation of the premises” during their natural lives or the life of the survivor is the reservation of a life estate in the premises: Armstrong v. Richener, 160 Pa. 21, 22 (1894); Saxton v. Mitchell, 78 Pa. 479 (1875); Stigers v. Dinsmore, 193 Pa. 482 (1899); Hall v. Dean, 72 Pa. Superior Ct. 599 (1919). In the Armstrong case there was a devise directing that a son “shall have for his own use and occupancy during the period of his life my [765]*765home farm . . with a gift over at his death. This was held to create a life estate.

The language of the reservation in this deed is entirely different from the language considered in the cases cited by plaintiff in his brief. The reservation here was of the use and the occupation of the entire premises. Had it been merely the reservation of the right to use the dwelling house or to live in the dwelling house, the situation would be different. What plaintiff acquired by the deed was the fee subject to a life estate in his parents or, stated differently, the remainder after the life estate. Was he then the unconditional and sole owner of the property? At the trial we thought he was not and, therefore, under the terms of the policy the policy was void.

A policy of fire insurance is a personal contract for indemnity against loss. “The insurance is not of the property as such, but of the interest of the insured in the property”: Spires v. Hanover Fire Insurance Company, 364 Pa. 52 (1950). The insured here did not insure his interest as remainderman, but attempted to insure the entire interest in the property. “The purpose of this provision (the sole and unconditional ownership clause in the policy) is, to prevent a party who holds an undivided or contingent but insurable interest in the property, from appropriating to his own use the proceeds of a policy, taken upon the valuation of the entire and unconditional title, as if he were the sole owner, and to remove from him the temptation to perpetrate fraud and crime. For without this, a person might thus be enabled to exceed the measure of an actual indemnity”: Imperial Fire Insurance Company v. Dunham, 117 Pa. 460, 475 (1888).

In that case the question was whether an equitable owner, as purchaser, was the sole and unconditional owner. It was held that he was, the court saying: “This provision of the policy does not necessarily distinguish [766]*766between the legal and the equitable estate. If the title is conditional or contingent, if it is for years only, or for life, or in common, it is not the entire, unconditional, and sole ownership; but the interest is the same, as it affects the contract of insurance, whether the title of the assured be legal or equitable.” This statement is, of course, dictum, but if an estate for life is not the entire unconditional and sole ownership, how can the remainder after the life estate be such?

In Livingstone v. Boston Insurance Company, 255 Pa. 1 (1916), the court defined the clause “sole and unconditional ownership” by saying: “The provisions of an insurance policy are construed favorably to the assured, and where he has an insurable interest and is the substantial owner of the property so that the entire loss falls on him, it satisfies the above quoted clause as to ownership, although he may not have a perfect legal title to the insured property.” In Commonwealth ex rel. Schwartz v. Bierly, 339 Pa. 213, 217 (1940), the court, in quoting this definition, emphasized the words, “the entire loss falls on him.”

In Kanefsky v. National Commercial Mutual Fire Insurance Company, 154 Pa. Superior Ct. 171, 175 (1943), the court said: “For reasons fully explained in our cases, the clauses relating to unconditional and sole ownership and title are enforced. They have been enforced and recovery has been denied in many factual situations. The following cases are typical instances: Porobenski v. American Alliance Ins. Co., 317 Pa. 410, 176 A. 205 (property held by husband and wife as tenants by the entireties insured in husband’s name); Bateman v. Lumbermen’s Ins. Co., 189 Pa. 465, 42 A. 184 (pledges of goods); Schroedel v. Humboldt Fire Insurance Co., 158 Pa. 459, 27 A. 1077 (property held by husband and wife jointly insured’ in husband’s name); Diffenbaugh v. Union Fire Ins. Co., 150 Pa. 270, 24 A. 745 (wife’s’ goods insured in husband’s [767]*767name); Schloss v. Importers and Exporters Ins. Co., 83 Pa. Superior Ct. 426 (automobile held under bailment lease upon which last installment was paid few days before loss); Goldberg v. Knickerbocker Ins. Co., 82 Pa. Superior Ct. 302 (automobile held under bailment lease); Chaney v. Farmer’s Fire Ins. Co., 32 Pa. Superior Ct. 479 (husband’s goods in possession of wife and daughter and insured in their name); Holmes v. Allemannia Fire Ins. Co., 77 Pa. Superior Ct. 337 (church property insured in individual names of trustees); Schiavoni v. Dubuque F. & M. Ins. Co., 48 Pa. Superior Ct. 252 (building and goods insured by lessees who owned goods but not building; no recovery for either); Elliott v. Teutonia Ins. Co., 20 Pa. Superior Ct. 359 (machinery in possession of insured under option to purchase); Duda v. Home Ins. Co., 20 Pa. Superior Ct. 244 (goods which the insured was required to leave upon premises at expiration of his lease).”

No case has been found after diligent search by counsel and an independent search by the court in which the factual situation of this case was presented. The reported cases indicate that the courts are inclined to go as far as possible to protect the insured who innocently takes a policy in his own name but later finds he is not technically the sole and unconditional owner of the property. However, when the situation is such that the insured is not actually the sole and unconditional owner, recovery must be denied. As stated in Schloss v. Importers and Exporters Ins. Co., 83 Pa. Superior Ct. 426, 428 (1924) : “As the insurance was conditioned on the assured’s sole and -unconditional ownership of the property and as such was not the fact when the policy was issued, it never went into force. . . -. That he had an insurable interest in the property is beside the question; he did not have the interest described and insured in-the policy.”

[768]*768In this case there is no suggestion of fraud on the part of plaintiff. He did have an insurable interest in the property and he did consider that he owned it. But he neglected to state that his parents had a life estate which took precedence over his right of enjoyment of the property.

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Related

SPIRES Et Ux. v. Hanover Fire Ins. Co.
70 A.2d 828 (Supreme Court of Pennsylvania, 1950)
Porobenski v. American Alliance Insurance
176 A. 205 (Supreme Court of Pennsylvania, 1934)
Commonwealth Ex Rel. Schwartz v. Bierly
13 A.2d 714 (Supreme Court of Pennsylvania, 1940)
Schloss v. Importers & Exporters Insurance
83 Pa. Super. 426 (Superior Court of Pennsylvania, 1924)
Goldberg v. Knickerbocker Ins. Co. of N.Y.
82 Pa. Super. 302 (Superior Court of Pennsylvania, 1923)
Kittelberger, Ex. v. Clearfield I. Co.
163 A. 367 (Superior Court of Pennsylvania, 1932)
Kanefsky v. National Commercial Mutual Fire Insurance
35 A.2d 766 (Superior Court of Pennsylvania, 1943)
Saxton v. Mitchell
78 Pa. 479 (Supreme Court of Pennsylvania, 1875)
Imperial F. Ins. v. Dunham
12 A. 668 (Supreme Court of Pennsylvania, 1888)
Diffenbaugh v. Union Fire Ins.
24 A. 745 (Supreme Court of Pennsylvania, 1892)
Schroedel v. Humboldt Fire Ins.
27 A. 1077 (Supreme Court of Pennsylvania, 1893)
Armstrong v. Michener
28 A. 447 (Supreme Court of Pennsylvania, 1894)
Collins ex rel. Hill v. London Assurance Corp.
30 A. 924 (Supreme Court of Pennsylvania, 1895)
Bateman v. Lumbermen's Insurance
42 A. 184 (Supreme Court of Pennsylvania, 1899)
Stigers v. Dinsmore
44 A. 550 (Supreme Court of Pennsylvania, 1899)
Livingstone v. Boston Insurance
99 A. 212 (Supreme Court of Pennsylvania, 1916)
Duda v. Home Insurance
20 Pa. Super. 244 (Superior Court of Pennsylvania, 1902)
Elliott v. Teutonia Insurance
20 Pa. Super. 359 (Superior Court of Pennsylvania, 1902)
Chaney v. Farmers' Fire Insurance
32 Pa. Super. 479 (Superior Court of Pennsylvania, 1907)
Schiavoni v. Dubuque Fire & Marine Insurance
48 Pa. Super. 252 (Superior Court of Pennsylvania, 1911)

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Bluebook (online)
14 Pa. D. & C.2d 763, 1958 Pa. Dist. & Cnty. Dec. LEXIS 410, Counsel Stack Legal Research, https://law.counselstack.com/opinion/benchoff-v-paradise-mutual-insurance-pactcompladams-1958.