1961, 1 SCRA 704

FACTS:

 Ang Ka Yu had a piece of property in his possession. He insured it with Phoenix.
 The property was lost, so Ang Ka Yu sought to claim the proceeds.
 Phoenix denied liability on the ground that Ang was not the owner but a mere possessor and as such, had no insurable interest over the property.

ISSUE:

Whether or not a mere possessor has insurable interest over the property.

HELD:

Yes. A person having a mere right or possession of property may insure it to its full value and in his own name, even when he is not responsible for its safekeeping. The reason is that even if a person is NOT interested in the safety and preservation of material in his possession because they belong to third parties, said person still has insurable interest, because he stands either to benefit from their continued existence or to be prejudiced by their destruction.

A person is said to have an insurable interest in the subject matter insured where he has a relation or connection with, or concern in it that he will derive pecuniary benefit or advantage from its preservation and will suffer pecuniary loss or damage from its destruction, termination, or injury by the happening of the event insured against.

*Case Digest by Honeyleth Luvie T. Hayag, Ll.B.-4, Andres Bonifacio Law School, SY 2018-2019