Court dismisses appeal holding that a training fee is a reciprocal obligation, not a penalty clause.

The Supreme Court dismissed the cassation appeal filed by an insurance company against a labor dispute judgment. The lower court ruled that a lump sum paid for legal training was a reciprocal obligation under the Civil Code, not a contractual penalty. Consequently, the plaintiff failed to prove actual damages, which are a prerequisite for claiming a penalty, rendering the penalty claim inadmissible.