Doña Adela Export International v. Trade

Summary

Doña Adela Export International filed for voluntary insolvency in 2006. After asset distribution agreements with creditors, TIDCORP and BPI included a provision in their compromise agreement requiring the company to waive bank deposit confidentiality under banking secrecy laws, despite the company not being a signatory. The RTC approved this agreement, holding the company bound by its silence during proceedings. The Supreme Court reversed, ruling that the company cannot be bound by a compromise agreement to which it was not a party. The Court emphasized that waiver of bank deposit confidentiality requires express written consent under RA 1405, cannot be implied from silence, and that compromise agreements bind only their signatories under the doctrine of relativity of contracts. This case establishes important precedent on the limits of compromise agreements in insolvency proceedings and protection of bank deposit secrecy rights.