Explain the three Case Digest from Facts to Ruling. (Use TagLish as a medium of explanation) HSBCL-SRP
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Explain the three Case Digest from Facts to Ruling. (Use TagLish as a medium of explanation)
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HSBCL-SRP v. Sps. Broqueza G.R. No. 178610, November 17, 2010 Justice Antonio T. Carpio FACTS: Respondent Hongkong Shanghai Banking Corporation, Ltd. Staff Retirement Plan includes Hongkong and Shanghai Banking Corporation (HSBC) employee, Editha Broqueza. She financed a vehicle in the sum of Php175,000.00 on October 1, 1990. She reapplied for and received a Php 24,000 appliance loan on December 12th, 1991. The payments on these loans are deducted straight from your paycheck. In the meanwhile, HSBC and its workers had a conflict in 1993. Editha Broqueza is only one of the many HSBC workers that lost their jobs. The workers subsequently took HSBC to the National Labor Relations Commission for what they said was an unlawful termination. As a result of being let off, Broqueza fell behind on the payments for her student loans and car. According to HSBCL-SRP's response, this meant her account was past due. Even after repeated requests for payment, Broqueza remained delinquent. After that, HSBCL-SRP took legal action against the Broquezas in civil court. Decision in favor of HSBCL-SRP was issued by the Metropolitan Trial - Court (MeTC). The MeTC decided that the requests for payment from HSBCL-SRP are of a civil character and are unrelated to the current labor dispute. The Regional Trial Court (RTC) decided that Broqueza was unable to receive retirement benefits due to her discharge from work. Because of this, the loans are now unprotected. Due to Editha Broqueza's ongoing default in payment and refusal to offer fresh security for her debts, HSBCL-SRP has every right to demand quick settlement of the overdue sum. In this case, the Court of Appeals overturned the RTC's ruling. ISSUE: When a dispute arises over the enactment of a loan agreement between an employer and an employee, which court has jurisdiction to hear the case? RULING: YES. The Court of Appeals (CA) is wrong. The Regional Trial Courts (RTC) ruled that since the Promissory Notes do not contain a period, HSBCL-SRP has the right to demand immediate payment. The spouses Broqueza admitted that prior to Editha's dismissal from HSBC in December 1993, she "religiously paid the loan amortizations, which HSBC collected through payroll check-off." Despite the spouses Broqueza's protestations, the payroll deduction is merely a convenient mode of payment and not the sole source of payment for the loans. HSBCL-SRP can immediately demand payment of the loans at anytime because the obligation to pay has no period. Additionally, the enforcement of a loan agreement involves "debtor-creditor relations founded on contract and does not in any way concern employee relations. As such, it should be enforced through a separate civil action in the regular courts and not before the Labor Arbiter. Art. 1179. Every obligation whose performance does not depend upon a future or uncertain event, or upon a past event unknown to the parties, is demandable at once. HSBCL-SRP v. Sps. Broqueza G.R. No. 178610, November 17, 2010 Justice Antonio T. Carpio FACTS: Respondent Hongkong Shanghai Banking Corporation, Ltd. Staff Retirement Plan includes Hongkong and Shanghai Banking Corporation (HSBC) employee, Editha Broqueza. She financed a vehicle in the sum of Php175,000.00 on October 1, 1990. She reapplied for and received a Php 24,000 appliance loan on December 12th, 1991. The payments on these loans are deducted straight from your paycheck. In the meanwhile, HSBC and its workers had a conflict in 1993. Editha Broqueza is only one of the many HSBC workers that lost their jobs. The workers subsequently took HSBC to the National Labor Relations Commission for what they said was an unlawful termination. As a result of being let off, Broqueza fell behind on the payments for her student loans and car. According to HSBCL-SRP's response, this meant her account was past due. Even after repeated requests for payment, Broqueza remained delinquent. After that, HSBCL-SRP took legal action against the Broquezas in civil court. Decision in favor of HSBCL-SRP was issued by the Metropolitan Trial - Court (MeTC). The MeTC decided that the requests for payment from HSBCL-SRP are of a civil character and are unrelated to the current labor dispute. The Regional Trial Court (RTC) decided that Broqueza was unable to receive retirement benefits due to her discharge from work. Because of this, the loans are now unprotected. Due to Editha Broqueza's ongoing default in payment and refusal to offer fresh security for her debts, HSBCL-SRP has every right to demand quick settlement of the overdue sum. In this case, the Court of Appeals overturned the RTC's ruling. ISSUE: When a dispute arises over the enactment of a loan agreement between an employer and an employee, which court has jurisdiction to hear the case? RULING: YES. The Court of Appeals (CA) is wrong. The Regional Trial Courts (RTC) ruled that since the Promissory Notes do not contain a period, HSBCL-SRP has the right to demand immediate payment. The spouses Broqueza admitted that prior to Editha's dismissal from HSBC in December 1993, she "religiously paid the loan amortizations, which HSBC collected through payroll check-off." Despite the spouses Broqueza's protestations, the payroll deduction is merely a convenient mode of payment and not the sole source of payment for the loans. HSBCL-SRP can immediately demand payment of the loans at anytime because the obligation to pay has no period. Additionally, the enforcement of a loan agreement involves "debtor-creditor relations founded on contract and does not in any way concern employee relations. As such, it should be enforced through a separate civil action in the regular courts and not before the Labor Arbiter. Art. 1179. Every obligation whose performance does not depend upon a future or uncertain event, or upon a past event unknown to the parties, is demandable at once.
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Economics of Money, Banking and Financial Markets
ISBN: 978-0321598905
9th Edition
Authors: Frederic S. Mishkin
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