Can a certificate of insurance policy be retroactive for an accident that occurred a few hours after the policy was purchased?

The plaintiffs also rely on Brochu v. Vachon, 2003 ABQB 820 [Brochu] where the owners of an all-terrain vehicle purchased insurance for it a few hours after their son was in an accident with it. The owners were unaware of the accident. The certificate of insurance stated that it was effective at 12:01 a.m. on the day it was purchased such that, on its face, it would provide coverage for the accident. The insurer argued that, despite the stated effective time, the policy could not be effective until it was purchased unless the parties had expressly agreed to retroactive coverage. The court found the agreement between the parties was unambiguously stated in the certificate of insurance which specified 12:01 a.m. as the time the policy came into effect. Thus, the policy covered the loss that had occurred earlier in the day before the policy was purchased.