01

Insurance Case Digest: Gulf Resorts Inc. v. Philippine Charter Insurance

Corp. (2005)
G.R. No. 156167 May 16, 2005
Lessons Applicable: Stipulations Cannot Be Segregated (Insurance)

FACTS:

Gulf Resorts, Inc at Agoo, La Union was insured with American Home
Assurance Company which includes loss or damage to shock to any of the
property insured by this Policy occasioned by or through or in consequence
of earthquake
July 16, 1990: an earthquake struck Central Luzon and Northern Luzon
so the properties and 2 swimming pools in its Agoo Playa Resort were
damaged
August 23, 1990: Gulf's claim was denied on the ground that its
insurance policy only afforded earthquake shock coverage to the two
swimming pools of the resort
Petitioner contends that pursuant to this rider, no qualifications were
placed on the scope of the earthquake shock coverage. Thus, the policy
extended earthquake shock coverage to all of the insured properties.
RTC: Favored American Home - endorsement rider means that only the
two swimming pools were insured against earthquake shock
CA: affirmed RTC

ISSUE: W/N Gulf can claim for its properties aside from the 2 swimming
pools

HELD: YES. Affirmed.

It is basic that all the provisions of the insurance policy should be

examined and interpreted in consonance with each other.
All its parts are reflective of the true intent of the parties.

Insurance Code
Section 2(1)
contract of insurance as an agreement whereby one undertakes for a
consideration to indemnify another against loss, damage or liability arising
from an unknown or contingent event
1
 An insurance premium is the consideration paid an insurer for
undertaking to indemnify the insured against a specified peril.
In the subject policy, no premium payments were made with regard to
earthquake shock coverage, except on the two swimming pools.

---

Gulf Resorts, Inc. v. Phil Charter Insurance, Corp.

G.R. No. 156167, 16 May 2005, 458 SCRA 550

FACTS:

Gulf Resorts, Inc at Agoo, La Union was insured with American Home
Assurance Company which includes loss or damage to shock to any of the
property insured by this Policy occasioned by or through or in consequence
of earthquake. On July 16, 1990, an earthquake struck Central Luzon and
Northern Luzon so the properties and 2 swimming pools in its Agoo Playa
Resort were damaged. On August 23, 1990, Gulf’s claim was denied on the
ground that its insurance policy only afforded earthquake shock coverage
to the two swimming pools of the resort. Petitioner contends that pursuant
to this rider, no qualifications were placed on the scope of the earthquake
shock coverage. Thus, the policy extended earthquake shock coverage to
all of the insured properties.The RTC Favored American Home
endorsement rider means that only the two swimming pools were insured
against earthquake shock the CA, affirmed RTC.

ISSUE:

W/N Gulf can claim for its properties aside from the 2 swimming pools

HELD:

YES. Affirmed.

It is basic that all the provisions of the insurance policy should be examined
and interpreted in consonance with each other. All its parts are reflective of
the true intent of the parties. Under Section 2 (1), contract of insurance as
an agreement whereby one undertakes consideration to indemnify another
2
against loss damages or liability arising from unknown or contingent
events. An insurance premium is the consideration paid an insurer for
undertaking to indemnify the insured against a specified peril. In the subject
policy, no premium payments were made with regard to earthquake shock
coverage, except on the two swimming pools.

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02

Western Guaranty v CA G.R. No. 91666 July 20, 1990

J. Feliciano

Facts:
Priscilla Rodriguez was struck by a bus owned by De Dios. She was
hospitalized and her face was permanently disfigured. Western Guaranty,
the insurance company of the bus line, was obliged to pay due to the bodily
injury caused by the bus. Rodriguez was able to earn a money judgment
from the court to the tune of 3000 for actual damages, 1500 for loss of
earning capacity, and 20000 for moral damages and attorney’s fees. De
Dios filed a complaint against Western to indemnify the amount. Western
lost the case in the appellate court, hence this petition.

Issue: Is Western liable for paying loss of earnings, moral damages and
attorney's fees even if these items are not among those included in the
Schedule of Indemnities set forth in the insurance policy.

Held: Yes. Petition dismissed.

Ratio:
The policy states:
Section 1. Liability to the Public — Company will, subject to the Limits of
Liability, pay all sums necessary to discharge liability of the insured in
respect of —
(a) death of or bodily injury to or damage to property of any
passenger as defined herein.
There was also a schedule of indemnities that specified a certain amount
for a certain type of injury as well as hospital service payments.
In this case, the limits on the amount payable for certain kinds of expenses
were not considered by the court as “excluding liability for any other type of
3
expense or damage or loss even though actually sustained or incurred by
the third party victim.”
The court noted that the limits of the liability was at 50,000 per person per
accident. Construing this with section 1 means that all kinds of damages
allowable by law were also to be covered by the policy once it was shown
that liability has arisen.
The schedule of indemnities was not a closed enumeration of the kinds of
damages Western can award.
Western should have used far more specific language, not the “pay all
sums necessary to discharge liability” clause.
Insurance contracts must be read by the courts with a jaundiced eye to
prevent the insurer from escaping from its obligation. Also, contracts of
adhesion such as policies msut be construed against the party who made
them, in this case western.

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WESTERN GUARANTY CORP. vs. COURT OF APPEALS

G.R. No. 91666 | July 20, 1990
Topic: Construction/Interpretation of Insurance Contracts
Feliciano, J.

FACTS:
• Private respondent Rodriguez was struck by a De Dios
Transportation Co. (DDTC) passenger bus while crossing a pedestrian lane
along Airport Road. The bus driver disregarded the stop signal of the traffic
policeman.
o Priscilla was thrown to the ground and was treated at the San Juan
De Dios hospital. Her face was permanently disfigured, causing her anxiety
and stress.
• DDTC was insured with petitioner Western Guaranty Corp., wherein
the Master Policy provided for protection against third party liability.
o “Company will, subject to the Limits of Liability, pay all sums
necessary to discharge liability of the insured in respect of death or bodily
injury or damage to property of any third party caused by or arising out of
the use of the vehicle…With respect to death of or bodily injury to any third
party or passenger, the company's payment per victim in any one accident
shall not exceed the limits indicated in the Schedule of Indemnities
provided for in this policy.”

4
• Rodriguez filed a complaint for damages in the RTC against DDTC,
which in turn, filed a third-party complaint against its insurance carrier
Western.
• Trial court ordered DDTC to pay actual and moral damages as well
as compensation for loss of earnings, and attorneys fees. Whatever may
be left unpaid by DDTC is to be paid by Western Guaranty by way of
contribution, indemnity or subrogation, to the extent of not more than
P50,000.
• Petitioner Western, in this Petition for Review, contends that it cannot
be held liable for loss of earnings, moral damages and attorney’s fees
because these items are not included in the Schedule of Indemnities set
forth in the insurance policy.
o Petitioner Western in effect contends that because the Schedule of
Indemnities limits the amount payable for certain kinds of expenses —
"hospital room", "surgical expenses", "operating room" and "medical
expenses" — that Schedule should be read as excluding liability for any
other type of expense or damage or loss even though actually sustained or
incurred by the third party victim.

ISSUE: W/N Western Guaranty is liable beyond the Schedule of

Indemnities set forth in the policy

HELD: Yes. The Schedule of Indemnities does not purport to limit, or to

enumerate exhaustively, the species of bodily injury occurrence of which
generate liability for Western.

PETITION DENIED.

RATIO:
• The Schedule doesn’t purport to restrict the kinds of damages that
may be awarded against Western once liability has arisen. All kinds of
damages allowable by law—actual or compensatory, moral, nominal,
liquidated, etc.—may be awarded against the insurer. Schedule of
Indemnities was not intended to be an enumeration, much less a closed
enumeration, of the specific kinds of damages which may be awarded
under the Master Policy Western has issued.
• The reading urged by Western of the Schedule of Indemnities comes
too close to working fraud upon both the insured and the third party
beneficiary. This would limit the otherwise unlimited and comprehensive
scope of liability assumed by Western under Sec. 1: “all sums necessary to
5
discharge liability of the insured in respect of [bodily injury to a third party].”
This reading will be repugnant to public policy. Western should have then
used more precise language if this is what they had intended, so that the
insured may be properly informed.
• Doctrine: It is well-settled that contractual limitations of liability found
in insurance contracts should be regarded by courts with a jaundiced eye
and extreme care and should be so construed as to preclude the insurer
from evading compliance with its just obligations. As a contract of
adhesion, insurance contracts should be construed strictly against the party
which prepared the contract.

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03

Finman General Assurance Corporation vs. C.A. (G.R. No. 100970.

September 02, 1992)
28 May

FINMAN GENERAL ASSURANCE CORPORATION, petitioner,

vs.
THE HONORABLE COURT OF APPEALS and JULIA SURPOSA,
respondents.

Aquino and Associates for petitioner.

Public Attorney’s Office for private respondent.

Ponente: NOCON

FACTS:

[P]etitioner filed this petition alleging grove abuse of discretion on the part
of the appellate court in applying the principle of “expresso unius exclusio
alterius” in a personal accident insurance policy since death resulting from
murder and/or assault are impliedly excluded in said insurance policy
considering that the cause of death of the insured was not accidental but
rather a deliberate and intentional act of the assailant in killing the former
as indicated by the location of the lone stab wound on the insured.

6
Therefore, said death was committed with deliberate intent which, by the
very nature of a personal accident insurance policy, cannot be indemnified.

ISSUE:

Whether or not death petitioner is correct that results from assault or

murder deemed are not included in the terms “accident” and “accidental”.

HELD:

NO. Petition for certiorari with restraining order and preliminary injunction
was denied for lack of merit.

RATIO:

The terms “accident” and “accidental” as used in insurance contracts have

not acquired any technical meaning, and are construed by the courts in
their ordinary and common acceptation. Thus, the terms have been taken
to mean that which happen by chance or fortuitously, without intention and
design, and which is unexpected, unusual, and unforeseen. An accident is
an event that takes place without one’s foresight or expectation — an event
that proceeds from an unknown cause, or is an unusual effect of a known
cause and, therefore, not expected.

[I]t is well settled that contracts of insurance are to be construed liberally in

favor of the insured and strictly against the insurer. Thus ambiguity in the
words of an insurance contract should be interpreted in favor of its
beneficiary.

FINMAN GENERAL ASSURANCE CORPORATION vs. THE

HONORABLE COURT OF APPEALS
FINMAN GENERAL ASSURANCE CORPORATION vs. THE
HONORABLE COURT OF APPEALS 213 SCRA 493, September 2, 1992
NOCON, J.:

FACTS:

On October 22, 1986, deceased, Carlie Surposa was insured with

petitioner Finman General Assurance Corporation with his parents,
7
spouses Julia and Carlos Surposa, and brothers Christopher, Charles,
Chester and Clifton, all surnamed, Surposa, as beneficiaries. While said
insurance policy was in full force and effect, the insured, Carlie Surposa,
died on October 18, 1988 as a result of a stab wound inflicted by one of the
three (3) unidentified men. Private respondent and the other beneficiaries
of said insurance policy filed a written notice of claim with the petitioner
insurance company which denied said claim contending that murder and
assault are not within the scope of the coverage of the insurance policy.
Private respondent filed a complaint with the Insurance Commission which
rendered a favorable response for the respondent. The appellate court
ruled likewise. Petitioner filed this petition alleging grave abuse of discretion
on the part of the appellate court in applying the principle of "expresso
unius exclusio alterius" in a personal accident insurance policy, since death
resulting from murder and/or assault are impliedly excluded in said
insurance policy considering that the cause of death of the insured was not
accidental but rather a deliberate and intentional act of the assailant.
Therefore, said death was committed with deliberate intent which, by the
very nature of a personal accident insurance policy, cannot be indemnified.

ISSUE: Whether or not the insurer is liable for the payment of the insurance
premiums

HELD:

Yes, the insurer is still liable. Contracts of insurance are to be construed

liberally in favor of the insured and strictly against the insurer. Thus
ambiguity in the words of an insurance contract should be interpreted in
favor of its beneficiary. The terms "accident" and "accidental" as used in
insurance contracts have not acquired any technical meaning, and are
construed by the courts in their ordinary and common acceptation. Thus,
the terms have been taken to mean that which happen by chance or
fortuitously, without intention and design, and which is unexpected,
unusual, and unforeseen. Where the death or injury is not the natural or
probable result of the insured's voluntary act, or if something unforeseen
occurs in the doing of the act which produces the injury, the resulting death
is within the protection of the policies insuring against death or injury from
accident. In the case at bar, it cannot be pretended that Carlie Surposa
died in the course of an assault or murder as a result of his voluntary act
considering the very nature of these crimes. Neither can it be said that
where was a capricious desire on the part of the accused to expose his life
8
to danger considering that he was just going home after attending a
festival. Furthermore, the personal accident insurance policy involved
herein specifically enumerated only ten (10) circumstances wherein no
liability attaches to petitioner insurance company for any injury, disability or
loss suffered by the insured as a result of any of the stimulated causes.
The principle of " expresso unius exclusio alterius" — the mention of one
thing implies the exclusion of another thing — is therefore applicable in the
instant case since murder and assault, not having been expressly included
in the enumeration of the circumstances that would negate liability in said
insurance policy cannot be considered by implication to discharge the
petitioner insurance company from liability for, any injury, disability or loss
suffered by the insured. Thus, the failure of the petitioner insurance
company to include death resulting from murder or assault among the
prohibited risks leads inevitably to the conclusion that it did not intend to
limit or exempt itself from liability for such death.

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04

Fortune v CA G.R. No. 115278 May 23, 1995

J. Davide Jr.

Facts:
Producers Bank’s money was stolen while it was being transported from
Pasay to Makati. The people guarding the money were charged with the
theft. The bank filed a claim for the amount of Php 725,000, and such was
refused by the insurance corporation due to the stipulation:
GENERAL EXCEPTIONS
The company shall not be liable under this policy in report of
(b) any loss caused by any dishonest, fraudulent or criminal act of the
insured or any officer, employee, partner, director, trustee or authorized
representative of the Insured whether acting alone or in conjunction with
others. . . .
In the trial court, the bank claimed that the suspects were not any of the
above mentioned. They won the case. The appellate court affirmed on the
basis that the bank had no power to hire or dismiss the guard and could
only ask for replacements from the security agency.

9
Issue: Did the guards fall under the general exceptions clause of the
insurance policy and thus absolved the insurance company from liability?

Held: Yes to both. Petition granted.

Ratio:
The insurance agency contended that the guards automatically became the
authorized representatives of the bank when they cited International
Timber Corp. vs. NLRC where a contractor is a "labor-only" contractor in
the sense that there is an employer-employee relationship between the
owner of the project and the employees of the "labor-only" contractor.
They cited Art. 106. Of the Labor Code which said:
Contractor or subcontractor. — There is "labor-only" contracting where the
person supplying workers to an employer does not have substantial capital
or investment in the form of tools, equipment, machineries, work premises,
among others, and the workers recruited and placed by such persons are
performing activities which are directly related to the principal business of
such employer. In such cases, the person or intermediary shall be
considered merely as an agent of the employer who shall be responsible to
the workers in the same manner and extent as if the latter were directly
employed by him.
The bank asserted that the guards were not its employees since it had
nothing to do with their selection and engagement, the payment of their
wages, their dismissal, and the control of their conduct.
They cited a case where an employee-employer relationship was governed
by (1) the selection and engagement of the employee; (2) the payment of
wages; (3) the power of dismissal; and (4) the power to control the
employee's conduct.
The case was governed by Article 174 of the Insurance Code where it
stated that casualty insurance awarded an amount to loss cause by
accident or mishap.
“The term "employee," should be read as a person who qualifies as such
as generally and universally understood, or jurisprudentially established in
the light of the four standards in the determination of the employer-
employee relationship, or as statutorily declared even in a limited sense as
in the case of Article 106 of the Labor Code which considers the employees
under a "labor-only" contract as employees of the party employing them
and not of the party who supplied them to the employer.”
But even if the contracts were not labor-only, the bank entrusted the
suspects with the duty to safely transfer the money to its head office, thus,
10
they were representatives. According to the court, “a ‘representative’ is
defined as one who represents or stands in the place of another; one who
represents others or another in a special capacity, as an agent, and is
interchangeable with ‘agent.’”

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Fortune Insurance and Surety Co., Inc. v. CA and Producers Bank of the
Philippines
G.R. No. 115278 May 23, 1995
Davide, Jr., J.

FACTS:
û Producers Bank was insured by Fortune Insurance.
û Producers Bank filed against Fortune Insurance a complaint for
recovery of the sum of P725,000.00 under the policy issued by Fortune.
The sum was allegedly lost during a robbery of Producer’s armored vehicle
while it was in transit to transfer the money from its Pasay City Branch to its
head office in Makati
û The said armored vehicle was robbed by its driver Benjamin
Magalong and security guard Saturnino Atiga tasked to man the same.
Both of them are not Producers Bank’s “employees” but were merely
assigned by and affiliated with PRC Management Systems and Unicorn
Security Services.
û Fortune Insurance refused to pay the amount as the loss, according
to it, is excluded from the coverage of the insurance policy. “General
Exceptions” provides: The company shall not be liable under this policy in
report of x x x (b) any loss caused by any dishonest, fraudulent or criminal
act of the insured or any officer, employee, partner, director, trustee or
authorized representative of the Insured whether acting alone or in
conjunction with others…”
û Producers Bank opposed the contention of Fortune Insurance and
contends that Atiga and Magalong are not its officer, employee, trustee, or
authorized representative at the time of the robbery.
û According to Fortune Insurance, when Producers commissioned a
guard and a driver to transfer its funds from one branch to another, they
effectively and necessarily became its authorized representatives in the
care and custody of the money. Assuming that they could not be
considered authorized representatives, they were, nevertheless,
employees of Producers.
11
ISSUE: WON Magalong and Atiga qualify as employees or authorized
representatives of Producers under paragraph (b) of the general exceptions
clause of the insurance policy as to exempt Fortune Insurance from liability
to pay Producers Bank under said policy

HELD: Yes.
û Employer-employee relationship depends upon four standards: (1)
the manner of selection and engagement of the putative employee; (2) the
mode of payment of wages; (3) the presence or absence of a power to
dismiss; and (4) the presence and absence of a power to control the
putative employee’s conduct
û The power of control over Magalong and Atiga was vested in and
exercised by Producers Bank; hence, an “employer-employee” relationship
exists between Magalong and Atiga and Producers Bank.
û PRC Management System and Unicorn Security Services are but
“labor-only” contractors (not employers) under Article 106 of the Labor
Code which provides: “There is “labor-only” contracting where the person
supplying workers to an employer does not have substantial capital or
investment in the form of tools, equipment, machineries, work premises,
among others, and the workers recruited and placed by such persons are
performing activities which are directly related to the principal business of
such employer. In such cases, the person or intermediary shall be
considered merely as an agent of the employer who shall be responsible to
the workers in the same manner and extent as if the latter were directly
employed by him.”
û Magalong and Atiga were, in respect of the transfer of Producers
Bank’s money from its Pasay City branch to its head office in Makati, its
“authorized representatives” who served as such with its teller Maribeth
Alampay. Howsoever viewed, Producers entrusted the three with the
specific duty to safely transfer the money to its head office, with Alampay to
be responsible for its custody in transit; Magalong to drive the armored
vehicle which would carry the money; and Atiga to provide the needed
security for the money, the vehicle, and his two other companions. In short,
for these particular tasks, the three acted as agents of Producers. A
“representative” is defined as one who represents or stands in the place of
another; one who represents others or another in a special capacity, as an
agent, and is interchangeable with “agent.”

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12
Fortune Insurance and Surety Co., Inc. v. Court of Appeals

G.R. No. 115278, 23 May 1995, 244 SCRA 308

FACTS:

Producers Bank was insured by Fortune Insurance.

Producers Bank filed against Fortune Insurance a complaint for recovery of
the sum of P725,000.00 under the policy issued by Fortune. The sum was
allegedly lost during arobbery of Producer’s armored vehicle while it was in
transit to transfer the money from itsPasay City Branch to its head office in
Makati

The said armored vehicle was robbed by its driver Benjamin Magalong and
security guardSaturnino Atiga tasked to man the same. Both of them are
not Producers Bank’s“employees” but were merely assigned by and
affiliated with PRC Management Systemsand Unicorn Security Services.

Fortune Insurance refused to pay the amount as the loss, according to it, is
excluded fromthe coverage of the insurance policy. “General Exceptions”
provides: The company shallnot be liable under this policy in report of x x x
(b) any loss caused by any dishonest,fraudulent or criminal act of the
insured or any officer, employee, partner, director, trusteeor authorized
representative of the Insured whether acting alone or in conjunction
withothers…”

Producers Bank opposed the contention of Fortune Insurance and

contends that Atiga andMagalong are not its officer, employee, trustee, or
authorized representative at the time of the robbery.

According to Fortune Insurance, when Producers commissioned a guard

and a driver totransfer its funds from one branch to another, they effectively
and necessarily became itsauthorized representatives in the care and
custody of the money. Assuming that theycould not be considered
authorized representatives, they were, nevertheless, employeesof
Producers.

ISSUE:

13
Wheter or not Magalong and Atiga qualify as employees or authorized
representatives of Producers under paragraph (b) of the general exceptions
clause of the insurance policy as toexempt Fortune Insurance from liability
to pay Producers Bank under said policy?

HELD:

Yes.
Employer-employee relationship depends upon four standards: (1) the
manner of selectionand engagement of the putative employee; (2) the
mode of payment of wages; (3) thepresence or absence of a power to
dismiss; and (4) the presence and absence of a powerto control the
putative employee’s conduct
The power of control over Magalong and Atiga was vested in and exercised
by ProducersBank; hence, an “employer-employee” relationship exists
between Magalong and Atigaand Producers Bank.
PRC Management System and Unicorn Security Services are but “labor-
only”contractors(not employers) under Article 106 of the Labor Code which
provides: “Thereis “labor-only” contracting where the person supplying
workers to an employer does nothave substantial capital or investment in
the form of tools, equipment, machineries, workpremises, among others,
and the workers recruited and placed by such persons areperforming
activities which are directly related to the principal business of such
employer.In such cases, the person or intermediary shall be considered
merely as an agent of theemployer who shall be responsible to the workers
in the same manner and extent as if thelatter were directly employed by
him.”Magalong and Atiga were, in respect of the transfer of Producers
Bank’s money from itsPasay City branch to its head office in Makati, its
“authorized representatives” whoserved as such with its teller Maribeth
Alampay. However viewed, Producers entrusted the three with the specific
duty to safely transfer the money to its head office, withAlampay to be
responsible for its custody in transit; Magalong to drive the armored vehicle
which would carry the money; and Atiga to provide the needed security for
the money, the vehicle, and his two other companions. In short, for these
particular tasks, the three actedas agents of Producers. A “representative”
is defined as one who represents or stands inthe place of another; one who
represents others or another in a special capacity, as anagent, and is
interchangeable with “agent.”

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14
 Insurance Case Digest: Fortune Insurance and Surety Co., Inc. v. CA
(1995)
G.R. No. 115278 May 23, 1995
Lessons Applicable: Stipulations Cannot Be Segregated (Insurance)

FACTS:

Producers Bank of the Philippines insured with Fortune Insurance and

Surety Co. P725,000 which was lost during a robbery of Producer's
armored vehicle while it was in transit from Pasay City City to its Makati
head office.
The armored car was driven by Benjamin Magalong Y de Vera, escorted
by Security Guard Saturnino Atiga Y Rosete.
After an investigation conducted by the Pasay police authorities, the
driver Magalong and guard Atiga were charged, together with Edelmer
Bantigue Y Eulalio, Reynaldo Aquino and John Doe, with violation of P.D.
532 (Anti-Highway Robbery Law)
Upon claiming, Fortune refused stating that it is not liable since under the
general exceptions of the policy:
any loss caused by any dishonest, fraudulent or criminal act of the
insured or any officer, employee, partner, director, trustee or authorized
representative of the Insured whether acting alone or in conjunction with
others. . . .
RTC: favored Producers Bank since Driver and Security Guard were
merely assigned
CA: Affirmed RTC

ISSUE: W/N the driver and security guard are employees under the general
exception

HELD: YES. Petition is granted.

It is clear to us that insofar as Fortune is concerned, it was its intention to

exclude and exempt from protection and coverage losses arising from
dishonest, fraudulent, or criminal acts of persons granted or having
unrestricted access to Producers' money or payroll. When it used then the
term "employee," it must have had in mind any person who qualifies as
such as generally and universally understood, or jurisprudentially
established in the light of the four standards in the determination of the
15
employer-employee relationship, 21 or as statutorily declared even in a
limited sense as in the case of Article 106 of the Labor Code which
considers the employees under a "labor-only" contract as employees of the
party employing them and not of the party who supplied them to the
employer
Producers entrusted the three with the specific duty to safely transfer the
money to its head office, with Alampay to be responsible for its custody in
transit; Magalong to drive the armored vehicle which would carry the
money; and Atiga to provide the needed security for the money, the
vehicle, and his two other companions.
A "representative" is defined as one who represents or stands in the
place of another; one who represents others or another in a special
capacity, as an agent, and is interchangeable with "agent."

16