What is the nature of a health care agreement? What is the effect of limited liability to health care agreements?

A health care agreement is in the nature of a non-­‐life insurance. It is an established rule in insurance contracts that when their terms contain limitations on liability, they should be construed strictly against the insurer. These are contracts of adhesion the terms of which must be interpreted andenforced stringently against the insurer which prepared the contract. This doctrine is equally applicable to health care agreements. (Blue Cross Health Care, Inc. vs. Noemi and Danilo Olivares, G.R. No. 169737, February 12, 2008 [Corona, J.], citing Philamcare Health Systems, Inc. vs. CA)