How have courts interpreted the phrase "any loss payable" in the offset clause of a life insurance policy?

Rejecting the insured's claim of an ambiguity in the phrase "any loss payable," the court said, "[W]e are not limited to the mere definition of the word ["loss"], but to the context in which it is used in [the offset clause] and the relationship of that clause to the others used in Section II." (Jarrett v. Allstate Ins. Co., supra, 209 Cal.App.2d at p. 811, 26 Cal.Rptr. 231.) Said the court, "It is not ambiguous or uncertain, but has obvious reference to the loss which is payable to the insured under the terms of Section II of the policy, and not to the loss which he suffers at the hands of the uninsured motorist." (Ibid.) Considering the ordinary and plain meaning of the word, the court said that "loss" was synonymous with the word "liability" and "was obviously so used here." (Id., at p. 812, 26 Cal.Rptr. 231.)