Insurance Death Claim Approval Timeline in the Philippines A practitioner-oriented legal guide (updated to 16 June 2025)
1 | Legal Sources that Fix or Influence Timelines
| Instrument | What it Says About Time | Key Provisions & Notes |
|---|---|---|
| Insurance Code of the Philippines (PD 612, as amended by RA 10607, 2013) | • Life (Sec. 249): Insurer must pay within 60 days after it receives due proof of death. • Non-life analogue (Sec. 248) applies to accident riders: pay within 30 days after proof and ascertainment; if loss is not yet ascertained >60 days, pay within 90 days of receiving proof. • Failure = interest at twice the prevailing 91-day Treasury-bill rate, reckoned from the day after the period lapses until full payment. |
The Code is the primary statute; riders attached to life policies (e.g., accidental death benefits) are treated as non-life for timing purposes. |
| Insurance Commission (IC) Circular Letters | • CL 2016-50 & CL 2022-73: insurers must acknowledge a filed claim or ask for missing papers within 15 calendar days of receipt. • Micro-insurance (CL 2018-01): once documents are complete, claims must be paid within 10 working days. • Claims Manual (CL 2013-14): mandates an internal workflow that lets the insurer decide within 30-day blocks. |
CLs are issued under Sec. 437 of the Code and are binding regulations. |
| Ease of Doing Business & Anti-Red Tape Act (RA 11032) | Government offices (including the IC when handling complaints) must resolve “complex” matters in ≤7 working days unless extended once for another 20. | Indirectly shapes how fast administrative dispute resolution moves. |
| Civil Code, Arts. 2200–2209 | Legal interest (now 6 % p.a. under BSP Cir. 799) applies on top of the double-T-bill surcharge if the Court finds unreasonable delay or bad faith. | Confirmed in Sun Life v. CA (G.R. No. 105135, 20 Jan 1994) and later cases. |
| Selected Supreme Court Cases | • Western Guaranty v. CA, G.R. No. 101271 (11 Feb 1995): affirmed 6 % interest from the date the claim should have been paid. • Philam Life v. CA, G.R. No. 100970 (20 Mar 1997): insurer’s 5-year investigation held unreasonable; Court enforced Code timelines. • Great Pacific (Grepalife) v. CA, G.R. No. 108727 (10 Apr 1997): clarified that filing a court case does not suspend the Code’s 60-day period unless the insurer validly contests the claim in writing within that period. |
High Court jurisprudence treats Code timelines as directory but compelling; unexplained delay = bad faith. |
2 | Chronology of a Typical Death-Benefit Claim
| Stage | Mandatory Clock | Practical Best Practice |
|---|---|---|
| 1. Notice of death | Policy conditions commonly require written notice within 30 days of death (not in the Code but contractual). Non-compliance is usually excused if insurer is not prejudiced. | Send e-mail and registered mail; get a receiving copy. |
| 2. Submission of “due proof” | No statutory period to file, but heirs should file ASAP; the Code’s 60-/30-/90-day clocks start only after insurer receives complete proof. | Follow the company’s claim kit; submit originals/certified copies. |
| 3. Acknowledgment / deficiency letter | 15 calendar days (IC CL 2022-73) to: (a) acknowledge; or (b) specify lacking documents. | Respond immediately; the clock pauses until papers are complete. |
| 4. Investigation & ascertainment | • Life claims: insurer must decide & pay within 60 days after complete proof (Sec. 249). • Accident/death riders (non-life): 30 days after proof if loss is already ascertained; otherwise, absolute deadline is 90 days from proof (Sec. 248). |
Medical reports, police records, toxicology, etc. should be ordered early. |
| 5. Written denial or contest (if any) | Must be issued within the same 60-/90-day window. Silence = implied approval. | Denial letter must state detailed grounds; otherwise later defenses may be barred (Philam Life rule). |
| 6. Payment of proceeds | Immediately but not later than the statutory deadline. Delay beyond the period automatically triggers interest: • Twice the 91-day T-bill rate (≈ 10–12 % in 2025) under the Code. • 6 % p.a. legal interest if court-awarded damages apply. |
Beneficiaries usually receive EFT or manager’s check. Keep proof of credit. |
| 7. Recourse if unpaid | • File a complaint with the IC (pecuniary limit: ≤ ₱5 million for life claims). • IC mediation is compulsory; adjudication follows if unresolved, target: 45 days. • Decisions appealable to the Court of Appeals via Rule 43 within 15 days. |
ARTA’s 7-day rule applies to IC’s internal processes. |
3 | Documentary “Due Proof of Death”
- Claimant’s Statement & Life-Insurance Claim Form
- Death Certificate registered with the Local Civil Registrar and PSA-certified.
- Police / Medico-Legal / Autopsy Report (for violent or sudden deaths).
- Attending Physician’s Statement (APS) + hospital abstracts.
- Original Policy / Certificate of Insurance (or affidavit of loss).
- KYC IDs of Beneficiaries + proof of relationship (marriage/birth certificate).
- Authority to Obtain Medical / Financial Records (Data Privacy Act compliant).
- Additional for Group Policies: Employer certification of coverage in force.
Tip for heirs: The 60-day statutory clock starts only after all required items acceptable to the insurer are in its hands, so anticipate and avoid “ping-pong” requests by giving a complete set in one filing.
4 | Special Time-Frames
| Scenario | Governing Rule | Deadline |
|---|---|---|
| Micro-insurance (premium ≤ 7.5 % of daily minimum wage) | IC CL 2018-01 | 10 working days after submission of complete claim papers. |
| Pre-need memorial plans | RA 9829 (Sec. 11) | 15 calendar days from filing of claim. |
| Overseas deaths | No extra statutory days, but insurers usually add maximum 30 days to gather foreign documents; must be in the Citizens’ Charter. | |
| Claims while policy is within the 2-year contestability period | Insurer may investigate “material misrepresentation.” Still bound by 60-/90-day outer limits unless it files a formal contest in court within the same period (Sec. 48, Insurance Code). |
5 | Consequences of Missing the Statutory Clock
Statutory Interest – automatically due without proof of bad faith:
- Twice the 91-day Treasury-bill rate (≈ 10–12 % p.a. in 2025) per Secs. 248-249.
Civil or Compensatory Interest – 6 % p.a. under Art. 2209 Civil Code when court finds unjustified delay (Western Guaranty).
Administrative Penalties – under Sec. 437: up to ₱200,000 per violation + ₱5,000/day of continuing offense; suspension of officers; even suspension of license.
Punitive Damages & Attorney’s Fees – when delay amounts to bad faith (Philam Life), courts award moral/punitive damages plus fees.
ARTA Sanctions – heads of agencies/officers may face dismissal for habitual neglect.
6 | Dispute-Resolution Timeline Overview
| Step | Time Allotment | Remarks |
|---|---|---|
| IC Mediation Notice | 3 days from docketing | Compulsory; non-appearance = waiver. |
| Mediation Proper | 30 days (extensible once, total 60) | Follows IC Mediation Rules. |
| Adjudication | Decision within 45 days after mediation ends | Executory after 15 days if no appeal. |
| Court of Appeals (Rule 43) | Petition within 15 days; CA decides 90 days from submission | CA’s judgment enforceable unless elevated to SC. |
7 | Practical Checklist for Beneficiaries
- Gather documents early – get PSA-certified death and birth/marriage certificates in one go.
- Submit via traceable channels – personal filing with receiving stamp, or registered mail/courier with tracking.
- Ask for an acknowledgment letter – forces the 15-day deficiency clock.
- Calendar the 60- or 90-day deadline – send a follow-up demand a week before expiry.
- Escalate to the IC promptly – it is faster and cheaper than filing in court.
8 | Compliance Pointers for Insurers
- Maintain a Citizens’ Charter that mirrors statutory clocks (RA 11032).
- Issue deficiency letters within 15 days – silence can estop later denials.
- Document every attempt to secure missing proofs – for possible IC audit.
- Pay partial, uncontested amounts even if a rider is disputed (Sun Life doctrine on separability of obligations).
- Automate Treasury-bill interest calculation – avoid compounding penalties.
9 | Bottom Line (At-a-Glance)
| Life Policy Claim | Accident/Non-life Death Rider | Micro-insurance Death |
|---|---|---|
| Pay within 60 days after complete proof of death. | Pay within 30 days if loss ascertained; 90 days absolute ceiling if ascertainment drags. | Pay within 10 working days after complete documents. |
| Interest: double TBILL + possible 6 % legal interest if delayed. | Same interest plus administrative fines for late payment. | Code interest still applies if late. |
The Philippine regulatory regime is claimant-protective: once heirs hand in a complete set of proofs, the insurer’s clock is short (30-, 60-, or 90-day windows). Missing the deadline is expensive, thanks to automatic double-T-bill interest, civil interest, and stiff IC fines. Conversely, heirs must file promptly and completely, because the statutory clock will not start until the proof is truly “due”—that is, received and sufficient under the policy and IC rules.
This article is for general information only and should not substitute for specific legal advice. For contentious or high-value claims, consult Philippine counsel or seek assistance from the Insurance Commission’s Public Assistance and Information Desk (PAID).