Here’s a practical, plain-English explainer on filing a complaint against an insurance company in the Philippines for claim delay—what to do, where to go, what to prepare, and what to expect. I’ll keep it comprehensive but usable, and I’ll flag spots where policy wording and the most recent circulars can change details (so you know what to double-check in your own documents).

1) First principles: your rights and where they come from

Insurance Code & Insurance Commission (IC). Philippine insurance companies (and, today, most HMOs and micro-insurers) are regulated by the Insurance Commission. The IC can hear and decide many policyholder complaints and impose administrative penalties for violations of the Code and IC circulars.
Contract governs—but not everything in a policy is absolute. The insurance policy is a written contract. Valid conditions (like notice requirements and time limits) will usually be enforced, but provisions that are unfair, illegal, or contrary to public policy can be struck down.
Good faith & fair claims handling. Insurers must handle claims promptly and fairly. IC circulars prohibit “unfair claims settlement practices” (e.g., ignoring communications, asking for obviously irrelevant documents, or unreasonably delaying payment).
Interest & damages for delay. If benefits are wrongfully withheld or payment is unduly delayed, courts/IC may award legal interest on the amount due and, in proper cases, damages and attorney’s fees (especially where bad faith is shown).
Jurisdictional amount. The IC’s adjudicatory power is subject to a monetary ceiling (historically raised by law). If your total claim (including damages) exceeds the current ceiling, the IC can still investigate for administrative violations, but you may need to sue in regular courts to recover the full amount. Check the latest ceiling in force when you file.

2) What counts as “claim delay”

A delay can be actionable when, for example:

The insurer misses the policy/IC-required timetable for acknowledging, investigating, or paying a claim (after you’ve submitted all reasonably required proofs).
The insurer keeps asking for piecemeal or irrelevant documents or goes silent despite follow-ups.
Liability is clear but payment is still not made within a reasonable time without valid reason (e.g., no genuine coverage dispute).

Important: “Delay” usually runs only after you’ve substantially complied with notice and proof-of-loss requirements. If the file is incomplete, the clock often hasn’t started.

3) Before you escalate: set yourself up to win

Do these steps first; they often solve delays and, if not, they make your case stronger:

Read the policy Focus on: coverage, exclusions, claim notice period, proof-of-loss requirements, medical or repair reports, “suit limitation” clause (often 12 months from denial), and any arbitration/ADR clause.
Complete the file Gather: policy/COC, IDs, premium receipts, incident report, photos, medical/repair bills, police/blotter (if applicable), proof of ownership/insurable interest, your prior emails/letters, and any adjuster’s reports.
Formal demand letter (very important) Send a dated, written demand to the insurer (copy the agent/broker) that:
- Lists the policy number and claim number
- Confirms you have submitted all requested documents (attach a checklist)
- States dates of follow-ups and any unanswered messages
- Asks for a decision or payment within a specific reasonable period
- Reserves your right to file with the IC and to claim interest and damages for delay.
Follow up in writing Keep a contact log (dates, names, phone/email, summary). Save screenshots of online portals.
Ask for the exact reason for any hold or denial You’re entitled to a clear explanation and the specific policy provision relied on.

4) Where to file the complaint

You have three main tracks (you can often pursue them in sequence):

A) Insurance Commission (administrative + adjudication)

Best when the amount is within the IC’s jurisdictional ceiling and you want a faster, specialized venue.
The IC can order the insurer to pay, impose fines, and penalize unfair claims practices.
The IC typically requires prior demand on the insurer and a complete set of supporting documents.

B) Regular courts (civil action)

Use this if (i) the amount exceeds the IC’s monetary jurisdiction, (ii) you want bad-faith damages beyond what the IC can award, or (iii) there’s a complex coverage dispute better suited for full trial.
Watch out for the policy’s suit-limitation clause (commonly one year from written denial). Courts often enforce these, so file in time.

C) ADR/Arbitration (if the policy says so)

Many corporate/commercial policies require arbitration. Some consumer policies include mediation/arbitration options.
Arbitration clauses can be enforceable; however, the IC still retains regulatory oversight (e.g., for unfair practices). Sometimes parties mediate at the IC before or alongside arbitration.

5) Filing with the Insurance Commission: how it works

What to prepare

Verified complaint (sworn statement). Identify the insurer, policy number, claim number, facts in date order, what was submitted and when, and the relief you seek (amount, interest, damages, penalties).
Attachments: policy/COC, endorsements, proof of premiums, claim forms, adjuster reports, medical/repair bills, photos, demand letters and replies (or proof of no reply), ID & authority (if through representative), and any police/incident reports.
Filing fee: depends on claim amount (bring cash/prepare to pay as assessed).
Service details: the insurer’s correct registered name and address (from your policy/correspondence).

Filing steps (typical flow)

Lodging & docketing at IC; your complaint gets a case number.
Preliminary evaluation; IC may request missing docs.
Summons/Answer; insurer is directed to respond.
Mediation/conciliation; many cases settle here when files are complete.
Conference/hearing & position papers; you present evidence; insurer explains the delay/denial.
Decision/Order; may direct payment (often with interest) and/or impose administrative fines and directives to improve claims handling.
Appeal/reconsideration; there are rules for motions and appeals to the Secretary of Finance/Court of Appeals, depending on the nature of the case and the relief awarded.

Timing expectations

Timeframes can vary based on completeness of your documents, insurer response, and docket load. Prompt, well-organized complaints move much faster.

6) What to ask for (relief)

Principal claim amount due under the policy
Legal interest for delay (state your reckoning date—e.g., from date of demand, or from date all required proofs were complete)
Consequential damages (if you can prove bad faith or specific losses caused by the delay)
Attorney’s fees/costs (when justified)
Administrative penalties against the insurer for unfair claims practices (within IC’s powers)

7) Strategy tips that materially improve outcomes

Master your timeline. Build a one-page chronology with four columns: Date | What happened | Evidence | Policy clause involved. Bring printed and digital copies.
Pin down “completeness.” Send a short letter/email asking the adjuster/claims handler to confirm in writing that your file is complete—or to list the final remaining items. This is critical for counting delay.
Stop the ping-pong. When new, arguably irrelevant requests pop up late in the process, respond promptly, say you’ll comply “without prejudice,” and note that the request is not material to coverage (if true).
Use your broker/agent, but document yourself. Third parties can help, but the insured should make key submissions and receive copies directly.
Mind prescription & suit limits. Calendar: (i) policy suit-limitation (often 12 months from written denial), (ii) general civil prescriptive periods on written contracts, and (iii) any arbitration filing deadline. Filing with the IC or entering mediation may toll (pause) certain periods, but don’t assume—calendar conservatively.

8) Special notes by product type

Motor & property (non-life). Adjuster reports and repair estimates are often the bottleneck. If liability is clear and the amount is small, push for partial payments or undisputed amounts while differences are resolved.
Life & accident. Medical proof and cause-of-death documents can be sensitive; ask the insurer to specify exactly which documents they still need and why they are material to coverage.
Health/HMO. Today many HMOs fall under IC oversight. Delays often involve pre-approval, reimbursement documentation, or provider billing disputes—document doctor/hospital confirmations and any HMO call reference numbers.
Microinsurance. These products are designed for simplicity and quick payout. If you’re being asked for complex requirements, challenge them as inconsistent with microinsurance standards.

9) Evidence pack checklist (print this)

Policy/COC + endorsements
Proof of premium payment (official receipts)
Claim notice (dates & method), claim forms
Proof of loss (medical, repair, photos, police/incident report)
Adjuster/assessor reports, estimates, invoices, receipts
Complete email thread and SMS/Viber screenshots (with timestamps)
Demand letter(s) & courier/email proof of delivery
Your contact log (calls, names, dates, notes)
Any denial/hold letters stating reasons and policy provisions cited
Government IDs; SPA/board resolution (if filing for another person/company)

10) Templates you can copy-paste

A) Demand for action/payment (send to insurer)

Subject: Policy [No. ______] – Claim [No. ______]: Demand for Action/Payment

Dear [Claims Officer/Insurer], I write regarding my claim under Policy No. [____]. I have submitted the required documents (see attached checklist) and completed these on [date]. Despite follow-ups on [dates], I have not received a final decision/payment.

Kindly confirm within [7/10/15] days (a) whether my file is complete, and (b) your decision. If approved, please release payment within the same period. If denied or held, please state the specific policy provision(s) and factual basis.

Absent timely resolution, I will elevate this to the Insurance Commission and seek legal interest and damages for the delay.

Sincerely, [Name, address, mobile, email]

B) Insurance Commission complaint (structure)

Parties (name/addresses; attach IDs)
Jurisdiction (policy issued in PH; claim amount within IC’s adjudicatory ceiling)
Facts in timeline form (bullet points with dates and exhibits)
Policy provisions (quote only the key ones)
Compliance (notice, proof-of-loss; attach evidence)
Unfair claims practices (silence, shifting requirements, etc.)
Relief (principal, interest from [date], damages, admin penalties, other just relief)
Verification & certification against forum shopping (notarized)

11) Frequently asked practical questions

Q: Do I need a lawyer to file with the IC? A: Not strictly—many consumers file pro se. For larger/complex claims, counsel helps, especially to preserve timelines, quantify interest/damages, and handle coverage controversies.

Q: Will filing with the IC ruin my relationship with the insurer? A: The IC provides a structured, professional forum. Many cases settle once the insurer is formally called to explain the delay.

Q: Can I still go to court if I start at the IC? A: Yes—but watch deadlines. A pending IC case may not automatically stop contractual suit-limitation periods. When in doubt, file protectively in court or seek an agreement to suspend deadlines.

Q: What interest rate applies? A: Philippine jurisprudence has standardized 6% per annum legal interest in many contexts; computation points (from demand, denial, or finality) can vary with the nature of the obligation. State your basis in your pleading and show your dates.

Q: The insurer says they’re waiting for their reinsurer. A: Reinsurance is the insurer’s issue, not yours. Your contract is with the insurer; it must pay per your policy and the law.

Quick action plan (one page)

Audit your file against the checklist; plug any gaps.
Send the formal demand with a firm response deadline.
If unresolved, prepare the IC complaint with sworn verification and attachments.
Calendar all deadlines (policy suit-limit, any ADR window, general prescription).
Decide whether to file only at IC, or IC + protective court filing (for big/complex claims).
At hearings/mediation, lead with the timeline and completeness confirmation; request interest and, if warranted, damages for bad faith.

If you want, I can turn this into a fill-in-the-blanks IC complaint package (verified complaint + exhibit index + demand letter) tailored to your case details—just share your policy type, claim amount, and the timeline of submissions.