Tag: Public Policy

  • Settlement Agreements: The Binding Force of Compromise in Resolving Disputes

    This case underscores the enforceability of compromise agreements in the Philippines, affirming that settlements reached by parties are binding when executed in good faith and not contrary to law, morals, public order, or public policy. The Supreme Court approved the compromise agreement between International School Manila and Spouses Aniñon, ending their legal battle, thus, reiterating the judiciary’s support for resolving disputes amicably and efficiently, promoting the stability and finality of settlements reached by parties in dispute.

    International School Manila: When Disputes Find Resolution Through Compromise

    In a dispute between International School Manila and Spouses Pedrito and Carmencita Aniñon, the parties sought resolution not through prolonged litigation, but through a compromise agreement. This agreement, presented before the Supreme Court, outlined terms acceptable to both parties, aiming to settle their differences stemming from a case involving alleged fraud by a school employee. The Supreme Court, in G.R. No. 166013, was tasked with evaluating and ruling on the validity of this agreement, ultimately deciding whether to uphold the autonomy of the parties in settling their dispute.

    The case originated from Civil Case No. 69088 and CA-G.R. SP No. 74110, eventually reaching the Supreme Court as SC-G.R. No. 166013. The dispute centered around a claim by Spouses Aniñon against International School Manila. Recognizing the potential benefits of a mutually agreeable settlement, both parties entered into a compromise agreement. This agreement detailed specific obligations and releases, demonstrating the parties’ intent to fully resolve their outstanding issues. The agreement stipulated that International School would pay Spouses Aniñon US$15,000.00 upon execution. Both parties also committed to jointly pursuing legal action against the individual allegedly responsible for the initial fraud, with International School taking the lead in prosecution, while Spouses Aniñon would provide assistance and documentation.

    The agreement also included provisions for the dismissal of pending cases before the Regional Trial Court and the Supreme Court. Both parties agreed to release each other from any further claims or liabilities related to the subject matter of the dispute. This mutual release was intended to provide finality and closure, preventing future litigation arising from the same set of facts. Central to the Court’s decision was the evaluation of whether the compromise agreement met the legal standards for validity. Under Philippine law, compromise agreements are contracts, and as such, must comply with the requisites for contracts. Article 1306 of the Civil Code provides that parties may establish stipulations, clauses, terms and conditions as they may deem convenient, provided they are not contrary to law, morals, good customs, public order, or public policy. In the instant case, the Supreme Court explicitly stated that the compromise agreement was found “not to be contrary to law, morals, good customs, public order and public policy.”

    In approving the agreement, the Court emphasized the policy of encouraging amicable settlements. This policy is rooted in the recognition that negotiated resolutions are often more efficient and satisfactory than imposed judicial outcomes. By upholding the validity of the compromise agreement, the Supreme Court reinforced the principle that parties are free to contract and to define the terms of their agreement, subject only to limitations imposed by law and public policy. The practical implication of this ruling is significant, encouraging litigants to explore settlement options and providing assurance that properly executed compromise agreements will be enforced by the courts. This contributes to reducing court congestion and promoting the efficient resolution of disputes.

    FAQs

    What was the main legal issue in the case? The primary issue was whether the compromise agreement entered into by International School Manila and Spouses Aniñon was valid and enforceable. This depended on whether the agreement complied with the legal requirements for contracts and whether it violated any laws or public policies.
    What is a compromise agreement under Philippine law? A compromise agreement is a contract where parties, by making reciprocal concessions, avoid litigation or put an end to one already commenced. It serves as a settlement of disputes, preventing or terminating lawsuits.
    What are the legal requirements for a valid compromise agreement? For a compromise agreement to be valid, it must meet the essential requisites of a contract: consent, object, and cause. Additionally, it must not be contrary to law, morals, good customs, public order, or public policy.
    What does it mean for a compromise agreement to be ‘not contrary to public policy’? An agreement is not contrary to public policy if it does not violate any established interests of society, such as justice, fairness, and the general welfare. It should not contravene any principles that protect the common good.
    Why did the Supreme Court approve the compromise agreement in this case? The Court approved the agreement because it found that it met all the legal requirements for validity and was not contrary to law or public policy. The Court also emphasized the policy of encouraging amicable settlements to promote efficient dispute resolution.
    What was the consideration exchanged between the parties in the compromise agreement? The consideration involved International School Manila agreeing to pay Spouses Aniñon US$15,000.00, and both parties agreeing to jointly pursue legal action against Marissa Bobon. Additionally, both parties released each other from further claims related to the dispute.
    What happens after the Supreme Court approves a compromise agreement? Once approved, the compromise agreement becomes a final and binding judgment. It is immediately executory, meaning the parties are legally obligated to comply with its terms, and the case is considered closed.
    Can a compromise agreement be challenged after it has been approved by the court? A compromise agreement can only be challenged on limited grounds, such as fraud, mistake, or duress. The burden of proving such grounds rests on the party challenging the agreement.

    The Supreme Court’s decision in International School Manila v. Spouses Aniñon reinforces the importance of compromise agreements in the Philippine legal system. By upholding the validity and enforceability of such agreements, the Court promotes amicable dispute resolution and reduces the burden on the judiciary. Parties are encouraged to explore settlement options, knowing that their agreements will be respected and enforced, provided they comply with the law and public policy.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: International School Manila v. Spouses Aniñon, G.R. No. 166013, June 08, 2005

  • Illegality as a Bar: When Both Parties are at Fault, Neither Can Seek Legal Remedy in Construction Disputes

    In a contract dispute, the Supreme Court ruled that when both parties are equally at fault in an illegal agreement, neither party can seek legal remedies from the other. This principle, known as pari delicto, prevents courts from resolving disputes arising from contracts that violate the law or public policy. The decision reinforces the importance of ensuring contractual agreements comply with all legal requirements to avoid being left without legal recourse.

    Construction Contracts and Complicity: When “Rough Finish” Turns Into a Rough Legal Outcome

    This case, Sps. Rufino Angel and Emerita Angel v. Simplicio Aledo and Felixberto Modales, arose from a construction agreement where the spouses Angel hired Felixberto Modales to build a two-story house. Due to Modales’ employment with the Department of Public Works and Highways, the contract was made under the name of his father-in-law, Simplicio Aledo. After disputes over payments and alleged construction defects, Aledo sued the Angels for unpaid balances, and the Angels filed a third-party complaint against Modales. The Court of Appeals ultimately dismissed both the claim and the third-party complaint, invoking the principle of pari delicto because the original agreement was structured to circumvent legal restrictions on Modales’ ability to contract with private parties. The Supreme Court upheld this decision.

    The central legal issue revolves around the applicability of Article 1412 of the Civil Code, which addresses situations where an unlawful or forbidden cause exists in a contract. This provision is crucial because it determines the rights of parties when their agreement is tainted by illegality. Specifically, the Court considered whether the Angels and Modales were equally at fault in entering into an agreement that violated public policy.

    The facts of the case revealed that both parties knowingly participated in structuring the contract in a manner that concealed Modales’ involvement, due to his government employment. This understanding and agreement was the lynchpin. The Supreme Court referenced the principle Ex dolo malo non oritur actio. In pari delicto potior est conditio defendentis meaning no cause of action arises from a wrongful act, and where both parties are equally at fault, the defendant is in a better position.

    The Court of Appeals relied on Article 1412(1) of the Civil Code, which states:

    ART. 1412. If the act in which the unlawful or forbidden cause consists does not constitute a criminal offense, the following rules shall be observed:

    (1) When the fault is on the part of both contracting parties, neither may recover what he has given by virtue of the contract, or demand the performance of the other’s undertaking…

    This provision highlights that when both parties are at fault, the law provides no remedy to either. The court’s reasoning emphasized that allowing either party to benefit from an illegal contract would undermine public policy and encourage further violations of the law. Thus, the Supreme Court agreed that, based on the established facts, both the Angels and Modales were aware of and participated in the illegal structuring of their agreement. The court looked at actions of both parties to determine the culpability of each party.

    The Supreme Court also addressed procedural issues raised by the petitioners. The Court agreed that the counterclaim of petitioners, which was compulsory, could not remain pending for independent adjudication by the court. With respect to petitioner’s argument that the Motion for Reconsideration of Modales was filed beyond the reglementary period. The Supreme Court found that because the motion was mailed within the proper timeframe it was permissible, because it is the date of mailing, not the date of receipt, of the mail matter, which shall be considered as the date of filing.

    Ultimately, the decision serves as a caution against entering into contracts that skirt legal requirements. The implications of this ruling are significant for anyone involved in contractual agreements, particularly in sectors where regulatory compliance is stringent. Individuals and businesses must ensure that their contracts are not only clear and comprehensive but also fully compliant with all applicable laws and regulations. Failing to do so could result in the loss of legal recourse in case of disputes.

    The practical takeaway from this case is clear: strict adherence to legal standards in contractual dealings is paramount. By understanding the principle of pari delicto and its potential consequences, parties can better protect their interests and avoid the pitfalls of unenforceable agreements. Contracts in regulated industries are especially at risk.

    FAQs

    What is the pari delicto principle? The pari delicto principle means that when both parties to a contract are equally at fault in an illegal transaction, neither can seek legal remedies against the other. The court will not assist either party in recovering losses or enforcing the agreement.
    Why was the construction agreement in this case considered illegal? The construction agreement was deemed illegal because it was intentionally structured to hide the involvement of Felixberto Modales, who was prohibited from entering into such contracts due to his government employment. Both parties were aware of this arrangement and participated in it.
    What was the main issue the Supreme Court addressed? The main issue was whether the Court of Appeals correctly applied the principle of pari delicto, thus barring the spouses Angel from recovering damages from Modales for alleged defects in the construction.
    What happens when a contract is found to be illegal? When a contract is found to be illegal, courts generally refuse to enforce it. If the parties are equally at fault, they are left as the court finds them, without any remedy available to either party.
    Could the spouses Angel recover damages for the faulty construction? No, the spouses Angel could not recover damages because they were deemed to be equally at fault in creating the illegal contract. The pari delicto principle prevented them from seeking any legal relief.
    How does Article 1412 of the Civil Code relate to this case? Article 1412 of the Civil Code provides the legal basis for the pari delicto principle. It states that when both contracting parties are at fault in an illegal act, neither can recover what they have given or demand performance from the other.
    What should parties do to avoid this situation in future contracts? Parties should ensure that all contractual agreements fully comply with all applicable laws and regulations. It is crucial to avoid structuring contracts to circumvent legal restrictions, as doing so may void the contract and remove legal recourse.
    Was the dismissal of Aledo’s appeal relevant to the final decision? Yes, as the Supreme Court addressed procedural issues raised by the petitioners in addition to whether the motion for reconsideration of Modales was filed beyond the reglementary period. However, Aledo’s standing was questionable as petitioners’ compulsory counterclaim could not be pending in the court.

    In conclusion, the Supreme Court’s decision reinforces the importance of legal compliance in contractual agreements. The principle of pari delicto serves as a strict reminder that knowingly participating in illegal contracts can have significant consequences, leaving parties without legal recourse. Ensuring transparency and adherence to the law in all contractual dealings is essential for protecting one’s legal and financial interests.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: SPS. RUFINO ANGEL AND EMERITA ANGEL VS. SIMPLICIO ALEDO AND FELIXBERTO MODALES, G.R. No. 145031, January 22, 2004

  • Enforceability of Consultancy Agreements: Influence Peddling and Public Policy

    The Supreme Court ruled in Marubeni Corporation vs. Lirag that an oral consultancy agreement predicated on exploiting personal influence with public officials is void and unenforceable. This means that individuals cannot legally claim fees from agreements where their primary service involves leveraging personal connections to influence government decisions, as such arrangements contravene public policy.

    When Personal Connections Trump Public Interest: The Case of Marubeni and Lirag

    This case revolves around a dispute over an alleged oral consultancy agreement between Felix Lirag and Marubeni Corporation, a Japanese company doing business in the Philippines. Lirag claimed he was promised a commission for helping Marubeni secure government contracts. The pivotal issue was whether such an agreement existed and, if so, whether it was enforceable, considering Lirag’s role involved leveraging his relationships with government officials.

    The Regional Trial Court (RTC) initially ruled in favor of Lirag, finding that he was entitled to a commission because he was led to believe an oral consultancy agreement existed and he performed his part by assisting Marubeni in obtaining a project. The RTC ordered Marubeni to pay Lirag P6,000,000.00 plus interest, attorney’s fees, and costs. The Court of Appeals (CA) affirmed the RTC’s decision, emphasizing the existence of a consultancy agreement based on the evidence presented and the principle of admission by silence, noting that Marubeni did not explicitly deny the agreement in their initial response to Lirag’s demand letter.

    However, the Supreme Court reversed these decisions, scrutinizing the evidence and legal principles involved. Central to the Supreme Court’s decision was the assessment of whether Lirag had proven the existence of the oral consultancy agreement by a preponderance of evidence, the standard required in civil cases. The court found that the evidence presented by Lirag was insufficient to conclusively establish that Marubeni had agreed to the consultancy. While Lirag presented corroborative witnesses, their testimonies primarily reflected what Lirag had told them, rather than direct evidence of an agreement with Marubeni.

    Even assuming an oral consultancy agreement existed, the Supreme Court highlighted a critical issue: the project for which Lirag claimed a commission was not awarded to Marubeni but to Sanritsu. Lirag argued that Marubeni and Sanritsu were sister corporations, implying that Marubeni indirectly benefited from the project. The court rejected this argument, stating that the separate juridical personality of a corporation could only be disregarded if used as a cloak for fraud, illegality, or injustice, none of which was convincingly established in this case. The Court quoted in the decision the testimony of Mr. Lito Banayo, whom respondent presented to corroborate his testimony on this particular issue:

    “ATTY. VALERO

    My question is- do you know for a fact whether the impression you have about Japanese Trading Firm working through Agents was the relationship between Marubeni and San Ritsu when Mr. Iida said that they were working together?

    “A: I did not know for a fact because I did not see any contract between Marubeni and San Ritsu presented to me.”

    Building on this, the Court addressed the nature of the services rendered by Lirag. It noted that Lirag admitted his role involved leveraging personal relationships with government officials, particularly Postmaster General Angelito Banayo, to facilitate meetings and establish goodwill for Marubeni. The Court referenced Lirag’s testimony, stating that his services were sought because Marubeni needed someone to help them “penetrate” and establish goodwill with the government. It further cited Lirag’s arrangement of meetings between Marubeni representatives and Postmaster General Banayo in Tokyo, facilitated through his intervention.

    The Supreme Court then invoked the principle that agreements based on exploiting personal influence with executive officials are contrary to public policy. Citing International Harvester Macleod, Inc. v. Court of Appeals, the Court emphasized that agreements contemplating the use of personal influence and solicitation, rather than appealing to the official’s judgment on the merits, are void. Such agreements undermine the integrity of public service and the fair administration of government contracts. According to the Court:

    “Any agreement entered into because of the actual or supposed influence which the party has, engaging him to influence executive officials in the discharge of their duties, which contemplates the use of personal influence and solicitation rather than an appeal to the judgment of the official on the merits of the object sought is contrary to public policy.”

    This ruling highlights the judiciary’s stance against agreements that prioritize personal connections over merit and transparency in securing government contracts. The decision reinforces the principle that public officials should make decisions based on the merits of a proposal, not on personal relationships or undue influence. Consequently, any agreement that facilitates or relies on such influence is deemed unenforceable. The Supreme Court underscored the importance of maintaining ethical standards in dealings with government officials, emphasizing that public service should be free from even the appearance of impropriety.

    The Supreme Court’s decision also clarified the application of the doctrine of admission by silence. While the Court of Appeals interpreted Marubeni’s initial response to Lirag’s demand letter as an implied admission of the consultancy agreement, the Supreme Court disagreed. It considered Marubeni’s explanation that its Philippine branch lacked the authority to enter into such agreements without approval from its headquarters in Tokyo. The Court found that Marubeni’s response indicated a need for internal review and did not constitute an admission of the agreement’s validity.

    In essence, the Supreme Court’s decision in Marubeni Corporation vs. Lirag serves as a reminder of the importance of upholding ethical standards in business dealings with the government. It emphasizes the unenforceability of agreements that rely on personal influence and solicitation, thereby safeguarding the integrity of public service and promoting fair competition. The case underscores the judiciary’s commitment to ensuring that government contracts are awarded based on merit, transparency, and the public interest, rather than on personal connections or undue influence.

    FAQs

    What was the key issue in this case? The key issue was whether an oral consultancy agreement existed between Lirag and Marubeni, and if so, whether it was enforceable given that it involved leveraging personal relationships to influence government decisions.
    What did the lower courts initially rule? The Regional Trial Court and the Court of Appeals both ruled in favor of Lirag, finding that an oral consultancy agreement existed and that Marubeni was liable to pay the agreed commission.
    Why did the Supreme Court reverse the lower courts’ decisions? The Supreme Court reversed the decisions because it found that Lirag had not proven the existence of the oral consultancy agreement by a preponderance of evidence and that the agreement, if it existed, was unenforceable because it was based on exploiting personal influence with public officials.
    What is the significance of “preponderance of evidence” in this case? “Preponderance of evidence” is the standard of proof required in civil cases, meaning the party must present enough credible evidence to convince the court that their version of the facts is more likely than not true; the Supreme Court found Lirag’s evidence lacking.
    What did the Court say about the relationship between Marubeni and Sanritsu? The Court rejected the argument that Marubeni and Sanritsu were so closely related that they should be considered one entity, stating that the separate juridical personality of a corporation could only be disregarded if it were used as a cloak for fraud, illegality, or injustice.
    What is the public policy issue involved in this case? The public policy issue is that agreements based on exploiting personal influence with executive officials are contrary to the public interest because they undermine fair competition and the integrity of public service.
    What is the doctrine of admission by silence, and how did it apply (or not apply) here? The doctrine of admission by silence states that a party’s silence in the face of an accusation can be taken as an admission; however, the Supreme Court found that Marubeni’s response to Lirag’s demand letter did not constitute an admission of the agreement’s validity.
    What is the practical implication of this ruling for consultants? The practical implication is that consultants cannot legally claim fees from agreements where their primary service involves leveraging personal connections to influence government decisions, as such arrangements are considered void and unenforceable.

    This case underscores the judiciary’s commitment to upholding ethical standards and preventing the exploitation of personal influence in government dealings. It serves as a crucial precedent for future cases involving consultancy agreements and the importance of maintaining transparency and fairness in securing government contracts.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Marubeni Corporation, vs. Felix Lirag, G.R. No. 130998, August 10, 2001

  • Contractual Waivers and Liability: When Can Banks Be Held Responsible for Negligence?

    Banks Can’t Contract Away Liability for Fraud or Bad Faith

    Philippine Commercial International Bank v. Court of Appeals and Rory W. Lim, G.R. No. 97785, March 29, 1996

    Imagine you’re sending money to a loved one overseas, relying on the bank’s promise of a swift transfer. But the money is delayed, causing significant financial hardship. Can the bank simply hide behind a clause in their agreement that absolves them of all responsibility? This case explores the limits of such contractual waivers, particularly when a bank acts negligently or in bad faith.

    In Philippine Commercial International Bank v. Court of Appeals, the Supreme Court tackled the issue of whether a bank could validly stipulate that it would not be responsible for losses due to errors or delays in telegraphic transfers, even if those errors or delays were caused by the bank’s own negligence. The court ultimately ruled that such waivers are unenforceable when the bank acts fraudulently or in bad faith, emphasizing that contracts cannot violate public policy.

    Understanding Contracts of Adhesion and Public Policy

    The case revolves around the concept of a “contract of adhesion,” which is a contract where one party (usually a large corporation) sets the terms, and the other party simply has to “take it or leave it.” While these contracts are generally valid, Philippine law recognizes that they can be problematic when the terms are unfair or oppressive, especially when one party has significantly more bargaining power than the other.

    A key principle at play here is that of “public policy.” This refers to the idea that certain contractual terms are simply unacceptable because they harm the overall well-being of society. For example, a contract that allows a party to profit from illegal activities would be against public policy and therefore unenforceable.

    Article 1409 of the Civil Code is very clear on this. It states: “The following contracts are inexistent and void from the beginning: (1) Those whose cause, object or purpose is contrary to law, morals, good customs, public order or public policy… These contracts cannot be ratified. Neither can the right to set up the defense of illegality be waived.”

    Here’s an example: Imagine a power company includes a clause in its service agreement stating it’s not liable for damages caused by power outages, even if those outages are due to the company’s negligence. Such a clause would likely be deemed against public policy because it would allow the power company to shirk its responsibility to provide reliable service, potentially endangering public safety.

    The PCIB Case: A Story of Delayed Transfers and Dishonored Checks

    The case began when Rory Lim purchased a telegraphic transfer from PCIB for P200,000, intending to send the money to his account at Equitable Banking Corporation in Cagayan de Oro. The funds were meant to cover checks he had issued to suppliers. However, PCIB delayed the transfer for 21 days, leading to the dishonor of Lim’s checks due to insufficient funds.

    The application form for the telegraphic transfer contained a clause stating that PCIB would not be responsible for any losses caused by errors or delays. PCIB argued that this clause protected them from liability.

    Here’s a breakdown of the key events:

    • March 13, 1986: Rory Lim purchases a telegraphic transfer from PCIB.
    • Lim issues checks to suppliers, expecting the transferred funds to cover them.
    • PCIB delays the transfer for 21 days due to internal errors.
    • Lim’s checks bounce, damaging his credit standing.
    • Lim sues PCIB for damages.

    The Regional Trial Court ruled in favor of Lim, finding the exculpatory clause invalid. The Court of Appeals affirmed this decision, albeit with modifications to the damages awarded. PCIB then appealed to the Supreme Court.

    The Supreme Court emphasized that PCIB’s actions amounted to bad faith, noting that “freedom of contract is subject to the limitation that the agreement must not be against public policy and any agreement or contract made in violation of this rule is not binding and will not be enforced.”

    The Court quoted Article 21 of the Civil Code, stating that “[a]ny person who willfully causes loss or injury to another in a manner that is contrary to morals, good customs or public policy shall compensate the latter for the damage.”

    The Court stated, “Any attempt to completely exempt one of the contracting parties from any liability in case of loss notwithstanding its bad faith, fault or negligence, as in the instant case, cannot be sanctioned for being inimical to public interest and therefore contrary to public policy.”

    What This Means for Banks and Customers

    This case sends a clear message to banks and other service providers: you cannot use contractual waivers to shield yourselves from liability when you act fraudulently, negligently, or in bad faith. The public has a right to expect a certain level of competence and integrity from these institutions, and the law will not allow them to escape responsibility for their misconduct.

    For customers, this case provides reassurance that they are not entirely at the mercy of large corporations. Even if you sign a contract with seemingly one-sided terms, the courts will scrutinize those terms to ensure they are fair and consistent with public policy.

    Key Lessons

    • Waivers are not absolute: Banks and other service providers cannot contract away liability for their own fraud, negligence, or bad faith.
    • Public policy matters: Contracts that violate public policy are unenforceable.
    • Customers have rights: Even in contracts of adhesion, customers have the right to fair treatment and recourse for damages caused by the other party’s misconduct.

    Frequently Asked Questions

    Q: What is a contract of adhesion?

    A: A contract of adhesion is a contract where one party sets the terms, and the other party simply has to accept them or reject the contract entirely.

    Q: Are contracts of adhesion always invalid?

    A: No, contracts of adhesion are generally valid, but courts will scrutinize them to ensure they are not unfair or oppressive, especially when one party has significantly more bargaining power.

    Q: What does it mean for a contract to be against public policy?

    A: A contract is against public policy if it violates the principles of law or morality that protect the overall well-being of society.

    Q: Can a bank be held liable for delays in fund transfers?

    A: Yes, a bank can be held liable for delays in fund transfers if the delays are caused by the bank’s negligence, fraud, or bad faith, even if there is a clause in the contract that attempts to limit the bank’s liability.

    Q: What should I do if I believe a bank has acted negligently in handling my funds?

    A: You should document all relevant information, including dates, amounts, and communications with the bank. Consult with a lawyer to discuss your legal options.

    ASG Law specializes in banking litigation and contract law. Contact us or email hello@asglawpartners.com to schedule a consultation.