- Petitioner
- Hongkong
- Respondent
- Spouses Bienvenido
- Citation
- G.R. No. 178610
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Carpio, J.
- Decided
- November 17, 2010
Summary
The Supreme Court ruled that loans without specified payment periods under promissory notes constitute pure obligations immediately demandable under Article 1179 of the Civil Code. HSBC employees Broqueza and Gerong obtained loans paid through salary deduction but defaulted after termination. The Court distinguished loan enforcement as civil debtor-creditor relations from employment issues, rejecting the Court of Appeals' finding that complaints were premature. The decision established that payroll deduction is merely a convenient payment mode, not the exclusive source, and creditors can demand immediate payment of pure obligations regardless of prior payment arrangements. This case clarifies the immediate demandability of contractual obligations lacking definite payment periods.