Geico, as an example, no longer cares if you park your car in a garage (secured) or not. I was explicitly told they no longer consider it statistically meaningful.
Instead, they go off statistics from the area code that your vehicle will generally be parked in and how far your commute to work is.
He wasn't parked in a garage before either. If the cost of insurance is based on risk, the fact that a tree falls on your car doesn't increase your risk. If anything, the risk in the future may be lower as presumably that tree isn't going to fall on the car again.
Instead, they go off statistics from the area code that your vehicle will generally be parked in and how far your commute to work is.