Citing my textbook, Credit Transactions: Notes and Cases, the Philippine Supreme Court, in Viva Shipping Lines, Inc. v. Keppel Philippines Mining, Inc., G.R. No. 177382, February 17, 2016 (Per J. Leonen, Second Division), said, inter alia:
"Clearly then, there are instances when corporate rehabilitation can no longer be achieved. When rehabilitation will not result in a better present value recovery for the creditors, the more appropriate remedy is liquidation."