Phillips, Admr. v. Prudential Ins. Co.

8 N.E.2d 450, 54 Ohio App. 554, 22 Ohio Law. Abs. 381, 54 Ohio C.A. 554, 8 Ohio Op. 298, 1935 Ohio App. LEXIS 342
CourtOhio Court of Appeals
DecidedOctober 4, 1935
StatusPublished

This text of 8 N.E.2d 450 (Phillips, Admr. v. Prudential Ins. Co.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Phillips, Admr. v. Prudential Ins. Co., 8 N.E.2d 450, 54 Ohio App. 554, 22 Ohio Law. Abs. 381, 54 Ohio C.A. 554, 8 Ohio Op. 298, 1935 Ohio App. LEXIS 342 (Ohio Ct. App. 1935).

Opinion

*382 OPINION

By NICHOLS, J.

Thomas Phillips, administrator of the estate of Margaret Phillips, deceased, plaintiff, brought his action against Tne Prudential Insurance Company of America, defendant, to recover the amount claimed due plaintiff from defendant on a life insurance policy issued by said company to Margaret Phillips. The policy involved was issued June 20th, 1927, and was in the amount of $1,000.00. The weekly premium was fifty-six cents, and the assured was twenty-five years of age at the date of issue.

The insured defaulted in the payment of said weekly premiums, and on November 28th, 1930 the policy being at that time thirty-six weeks in arrears the policy was renewed by the assured, executing ar.d delivering to the company a premium note in the sum of $20.16, which indebtedness became a lien on the policy, effective December 8th, 1930. Thereafter current premiums were paid to and including June 15th, 1931, and by reason thereof the policy was in full force and effect until June 22nd, 1931. After June 22nd, 1931, no further premiums were paid, nor were any payments ever made on the premium note.

The assured died April 17, 1933, and payment of any amount of the policy having been refused by the company, on the ground that the policy had lapsed and the coverage had expired before the death of the assured, this action was filed in the Common Pleas Court.

The issues were presented to the Common Pleas Court upon the pleadings and the evidence, a jury being waived by the parties, and said court finding in favor of the defendant. Error is prosecuted to this court, the parties remaining in the same relative position as in the court below, and will be referred to respectively as the assured and the company.

In determining whether the Common Pleas Court erred in finding for the defendant, two questions are presented: First, what was the length of the extended term insurance which was automatically placed in effect when the assured ceased paying premiums on June 22nd, 1931; Second was there any duty on the part of the company to give notice that the policy automatically lapsed or was terminated for non-payment of premiums?

It is conceded by the parties that the policy having lapsed on June 22nd, 1931, the assured became automatically emiueu to non-participating extended insurance for a certain term, it being likewise conceded by the parties that the assured did nos surrender said policy nor elect to take the cash surrender value thereof or a paid up life policy in accordance with the option set forth in the policy. The record likewise shows the parties in accord upon the proposition that under the standard industrial experience table, with 3%% interest per annum, as provided for in the policy, the amount available for extended term insurance at the time said policy lapsed was $30.09, and that this amount, if the indebtedness of the assured is not to be deducted first therefrom, was sufficient to extend the insurance for the period of two years and forty-two weeks next after June 22nd, 1.931, making the expiration date subsequent to the death of the assured, but if the indebtedness of the assured to the company is first to he deducted from this sum of $30.09, there would remain only $9.93 available for extended term insurance, which sum of $9.93 was sufficient to extend the insurance only for the period of forty-eight weeks next after June 22nd, 1931. making the expiration date of the extended term insurance May 16th, 1932, before the death of the assured.

The question is, therefore, resolved into one whether or not the amount of the indebtedness of the assured to the company is first to be deducted from the- non-forfeiture value of the policy before the term of the extended insui'ance is computed, or whether the full non-forfeiture value of the policy is to be used in computing the term of extended insui'ance and the company relegated to the position of deducting from the face of the policy at the death of the assured the amount of indebtedness of the assured to it.

To determine this question we lirst look to the provisions of the policy, which is the contract between the parties. From the policy we quote the applicable language thereof:

“If there be any indeotedness under this policy, such indebtedness will be deducted from the cash surrender value, or the term of the extended insurance or the amount of the paid-up life policy will be reduced to such term or amount as the net single premium value of the respective provisions reduced by such indebtedness shall provide, according to the mortality table hereinafter specified.” (Standard industrial mortality table).

*383 As above stated, at the time the assured stopped paying premiums and the policy lapsed, the assured did not exercise any of the options granted to her in the policy, which were to surrender the policy within three months after such lapse and receive either a non-participating pai'd-up life policy or payment in cash as specified in the table incorporated in the policy. Therefore, if we strike from the above quoted provisions of the policy applicable to cases where assured has made an election of options and leave only the provisions of the policy in case where the assured has done nothing, we read:

“If there be any indebtedness under this policy, such indebtedness will be deducted from the *- '• * term of the extended insurance ’ ’ * at the net single premium value ‡ * * reduced by such indebtedness shall provide, according to the mortality table hereinafter specified.”

This language is not ambiguous and clearly provides that the indebtedness of the assured to the company in the amount of $20.16, and interest, shall first be deducted from the $30.09 non-forfeiture value of the policy, leaving only $9.93 available for computing the term of extended insurance.

Let us see to what situation the company would be relegated if we were to adopt a construction of this language to the effect that the whole sum of $30.09 should be used in computing the duration of the extended term, and then let us suppose that the assured lived longer than the limit of this extended term so that the coverage had entirely ended before the death of the assured. It is seen that in such event there would be nothing from which the company could deduct the amount of the indebtedness of the assured to it, and its lien would be lost.

We are further confirmed in our eonclusion of this matter by the language of the note given by the assured to the company for the amount of the indebtedness of the assured to the company, which provides as follows:

“That if said policy shall lapse or become forfeited in any manner, the said amount, with interest accrued thereon, shall be deducted from the cash surrender value of the said policy, and the amount, with interest accrued thereon, shall operate to reduce the amount of any paid-up life or endowment policy or to reduce the term of extended insurance (if any) granted by the terms of said policy in accordance with the rules of the company.”

Plaintiff in error calls our attention to the ease of National Benefit Life Insurance Co. v Hatcher, decided by the Court of Appeals for this district November 4th, 1932, reported in 14 Abs 313, the syllabus reading:

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Related

National Benefit Life Insurance v. Hatcher
14 Ohio Law. Abs. 313 (Ohio Court of Appeals, 1932)

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Bluebook (online)
8 N.E.2d 450, 54 Ohio App. 554, 22 Ohio Law. Abs. 381, 54 Ohio C.A. 554, 8 Ohio Op. 298, 1935 Ohio App. LEXIS 342, Counsel Stack Legal Research, https://law.counselstack.com/opinion/phillips-admr-v-prudential-ins-co-ohioctapp-1935.