Case Digest (G.R. No. L-554) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Haw Pia v. China Banking Corporation (80 Phil. 604, G.R. No. L-554, April 9, 1948), plaintiff-appellant Haw Pia sued respondent-appellee China Banking Corporation in the Court of First Instance of Manila to compel cancellation of a mortgage over TCT No. 47634, delivery of the title with the mortgage duly cancelled, and P1,000.00 as attorney’s fees plus costs. Haw Pia admitted an overdraft indebtedness of P5,103.35 with accrued interest, which she alleged to have fully paid, between October 7, 1942, and August 29, 1944, in Japanese military notes to the Bank of Taiwan, Ltd., appointed by the Japanese Military Administration as liquidator of China Banking Corporation. In its answer, the bank denied authorizing the Bank of Taiwan to receive payment and filed a counterclaim for P5,103.35 plus interest at 9% compounded monthly, P1,500.00 attorney’s fees, and costs. The trial court ruled that the liquidation was an unauthorized confiscation under Article 46 of the 1907 Hague Regula Case Digest (G.R. No. L-554) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Parties
- Haw Pia obtained an overdraft facility of ₱8,000 from China Banking Corporation, secured by mortgage on her Manila real property (TCT No. 47634).
- By December 26, 1941, her unpaid balance, including interest, was ₱5,103.35.
- Japanese Occupation and Liquidation
- On January 2, 1942, Japanese Military Administration appointed Bank of Taiwan as liquidator of “enemy” banks, including China Banking Corporation, under Administrative Ordinance No. 11.
- From October 7, 1942, to August 29, 1944, Haw Pia paid Bank of Taiwan ₱6,055.21 in Japanese military notes, believing these extinguished her debt.
- Post-Liberation Proceedings
- On August 31, 1945, Haw Pia sued China Banking Corporation to cancel the mortgage and return her title, claiming full payment.
- The bank counterclaimed for ₱5,103.35 plus interest, attorney’s fees of ₱1,500, and costs.
- Trial court held the Japanese administration lacked authority to liquidate, declared payments invalid, and ordered foreclosure if Haw Pia failed to pay within 90 days after moratorium lift.
- Haw Pia appealed to the Supreme Court.
Issues:
- Authority to Liquidate
- Did the Japanese Military Administration have authority under international law to order the liquidation of China Banking Corporation and appoint Bank of Taiwan as its liquidator?
- Effect of Payments
- If so, did the payments made by Haw Pia to Bank of Taiwan in Japanese military notes validly extinguish her obligation to China Banking Corporation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)