Scribd Logo
Upload

Welcome to Scribd!

  • 103 views

    International Exchnage Bank vs. Sps. Briones

    Uploaded by

    k santos
    The RTC dismissed iBank's complaint against the Spouses Briones, ruling that as their attorney-in-fact, iBank had an obligation to file an insurance claim for the lost vehicle but failed to do so. The RTC also found that iBank prioritized its own interests over its principals by not filing the claim. The Supreme Court affirmed, finding that the agency relationship was not revoked when the Spouses Briones filed the claim directly with the insurance company due to iBank's negligence. As the agency was established for the benefit of both parties through their bilateral contract, it was considered irrevocable.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    International Exchnage Bank vs. Sps. Briones

    Uploaded by

    k santos
    103 views2 pages
    The RTC dismissed iBank's complaint against the Spouses Briones, ruling that as their attorney-in-fact, iBank had an obligation to file an insurance claim for the lost vehicle but failed to do so. The RTC also found that iBank prioritized its own interests over its principals by not filing the claim. The Supreme Court affirmed, finding that the agency relationship was not revoked when the Spouses Briones filed the claim directly with the insurance company due to iBank's negligence. As the agency was established for the benefit of both parties through their bilateral contract, it was considered irrevocable.

    Original Description:

    Original Title

    2. International Exchnage Bank vs. Sps. Briones

    Copyright

    © © All Rights Reserved

    Available Formats

    DOCX, PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    The RTC dismissed iBank's complaint against the Spouses Briones, ruling that as their attorney-in-fact, iBank had an obligation to file an insurance claim for the lost vehicle but failed to do so. The RTC also found that iBank prioritized its own interests over its principals by not filing the claim. The Supreme Court affirmed, finding that the agency relationship was not revoked when the Spouses Briones filed the claim directly with the insurance company due to iBank's negligence. As the agency was established for the benefit of both parties through their bilateral contract, it was considered irrevocable.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    103 views2 pages

    International Exchnage Bank vs. Sps. Briones

    Uploaded by

    k santos
    The RTC dismissed iBank's complaint against the Spouses Briones, ruling that as their attorney-in-fact, iBank had an obligation to file an insurance claim for the lost vehicle but failed to do so. The RTC also found that iBank prioritized its own interests over its principals by not filing the claim. The Supreme Court affirmed, finding that the agency relationship was not revoked when the Spouses Briones filed the claim directly with the insurance company due to iBank's negligence. As the agency was established for the benefit of both parties through their bilateral contract, it was considered irrevocable.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    ● RTC dismissed iBank's complaint.

    It ruled that as the duly constituted


    2. International Exchnage Bank vs. Sps. Briones attorney-in- fact of the Spouses Briones, iBank had the obligation to
    GR NO. 205657 facilitate the filing of the notice of claim and then to pursue the release of
    March 29, 2017 the insurance proceeds.
    ● The Regional Trial Court also pointed out that as the Spouses Briones'
    Topic: ATP agent, iBank prioritized its interest over that of its principal when it failed
    Petitioners: International Exchange Bank to file the notice of claim with the insurance company and demanded full
    Respondents: SPS. BRIONES payment from the spouses.
    Ponente: LEONEN, J
    ● Petitioner maintains that the insurance coverage taken on the vehicle is
    "only an aleatory alternative that respondents are entitled to" if their
    RECIT-READY
    claim is granted by the insurance company. Petitioner asserts that it was
    the duty of Briones to file a claim with the insurance company. Thus, they
    should not be allowed to pass on that responsibility and they should be
    held liable for the loan taken out on the lost vehicle.
    ● Moreover, petitioner posits that respondent Jerome's direct dealing with
    the insurance company was a revocation of the agency relationship
    DOCTRINE: Revocation as a form of extinguishing an agency under Article 1924 of between petitioner and respondents
    the Civil Code only applies in cases of incompatibility, such as when the principal
    disregards or bypasses the agent in order to deal with a third person in a way that ISSUE
    excludes the agent. (1) whether the agency relationship was revoked or terminated? (No)

    FACTS HELD/RATIO

    ● Sps. Briones contracted a loan in the amount of 3.8m with Ibank with a (1) No. The Spouses Briones' claim for loss cannot be seen as an implied
    monthly amortization of 79k. They used it to buy a BMW Z4 Roadster. revocation of the agency or their way of excluding petitioner. They did
    not disregard or bypass petitioner when they made an insurance claim;
    ● The Spouses Briones executed a promissory note with chattel mortgage rather, they had no choice but to personally do it because of their agent's
    that required them to take out an insurance policy on the vehicle.The negligence. This is not the implied termination or revocation of an agency
    promissory note also gave iBank, as the Spouses Briones' attomey-infact, provided for under Article 1924 of the Civil Code. 
    irrevocable authority to file an insurance claim in case of loss or damage
    to the vehicle. The insurance proceeds were to be made payable to iBank. (2) While a contract of agency is generally revocable at will as it is primarily
    ● The BMW was carnapped and it was reported by Briones to the Police based on trust and confidence, Article 1927 of the Civil Code provides the
    and eventually declared the loss to ibank. As a proof of good faith, ibank instances when an agency becomes irrevocable: 
    “Article 1927. An agency cannot be revoked if a bilateral contract depends
    told them to continue paying the installments for the next 3 months.
    upon it, or if it is the means of fulfilling an obligation already contracted, or if a
    ● After 3 months, ibank sent them a letter demanding the full payment of partner is appointed manager of a partnership in the contract of partnership and
    the lost vehicle his removal from the management is unjustifiable. “
    (3) A bilateral contract that depends upon the agency is considered an
    ● On April 30, 2004, the Spouses Briones submitted a notice of claim with agency coupled with an interest, making it an exception to the general
    their insurance company, which denied the claim on June 29, 2004 due to rule of revocability at will.Lim v. Sabanemphasizes that when an agency is
    the delayed reporting of the lost vehicle. established for both the principal and the agent, an agency coupled with
    an interest is created and the principal cannot revoke the agency at will.
    (4) In the promissory note with chattel mortgage, the Spouses Briones
    authorized petitioner to claim, collect, and apply· the insurance proceeds
    towards the full satisfaction of their loan if the mortgaged vehicle were
    lost or damaged. Clearly, a bilateral contract existed between the parties,
    making the agency irrevocable. Petitioner was also aware of the bilateral
    contract; thus, it included the designation of an irrevocable agency in the
    promissory note with chattel mortgage that it prepared for the Spouses
    Briones to sign.

    You might also like