International Exchange Bank v. Sps Briones

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G.R. No.

205657

INTERNATIONAL EXCHANGE BANK NOW UNION BANK OF THE PHILIPPINES, Petitioner


vs
SPOUSES JEROME AND QUINNIE BRIONES, AND JOHN DOE, Respondents

FACTS

 Spouses Briones took out a loan of ₱3,789,216.00 from iBank to purchase a BMW Z4
Roadster.
 The Spouses Briones executed a promissory note with chattel mortgage that required
them to take out an insurance policy on the vehicle.8 The promissory note also gave
iBank, as the Spouses Briones' attomey-infact, irrevocable authority to file an
insurance claim in case of loss or damage to the vehicle.9 The insurance proceeds
were to be made payable to iBank.10
 Later, the mortgaged BMW Z4 Roadster was carnapped. The Spouses Briones declared
the loss to iBank, which instructed them to continue paying the next three (3) monthly
installments "as a sign of good faith," a directive they complied with.13
 after the Spouses Briones finished paying the three (3)-month installment, iBank sent
them a letter demanding full payment of the lost vehicle.
 The Spouses Briones submitted a notice of claim with their insurance company,
which denied the claim on June 29, 2004 due to the delayed reporting of the lost
vehicle.1
 The Regional Trial Court pointed out that as the Spouses Briones' agent, iBank
prioritized its interest over that of its principal when it failed to file the notice of
claim with the insurance company and demanded full payment from the spouses.
 The CA upheld the RTC decision
ISSUE
WON the petitioner is liable to the respondents for failure to file notice of claim with the
insurance company.
RULING
All the elements of agency exist in this case. Under the promissory note with chattel mortgage,
Spouses Briones appointed iBank as their attorney-in-fact, authorizing it to file a claim with the
insurance company if the mortgaged vehicle was lost or damaged.48 Petitioner was also
authorized to collect the insurance proceeds as the beneficiary of the insurance policy.
Article 1884 of the Civil Code provides that "the agent is bound by his acceptance to carry out
the agency, and is liable for the damages which, through his non-performance, the principal
may suffer."
As the agent, petitioner was mandated to look after the interests of the Spouses Briones.
However, instead of going after the insurance proceeds, as expected of it as the agent,
petitioner opted to claim the full amount from the Spouses Briones, disregard the established
principal-agency relationship, and put its own interests before those of its principal.
The facts show that the insurance policy was valid when the vehicle was lost, and that the
insurance claim was only denied because of the belated filing.1âwphiHaving been negligent in
its duties as the duly constituted agent, petitioner must be held liable for the damages suffered
by the Spouses Briones because of non-performance65 of its obligation as the agent, and
because it prioritized its interests over that of its principal.

If petitioner was indeed acting in good faith, it could have timely informed the Spouses Briones
that it was terminating the agency and its right to file an insurance claim, and could have
advised them to facilitate the insurance proceeds themselves. Petitioner's failure to do so only
compounds its negligence and underscores its bad faith. Thus, it will be inequitable now to
compel the Spouses Briones to pay the full amount of the lost property.

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