Philippine Export & Foreign Loan Guarantee Corp. v. Chuidian (1990) 218 Cal. App. 3d 1058, involved an action by a Philippine government-owned entity against an individual and his corporations seeking to enforce loan guarantees from the Philippine entity. A settlement of the litigation provided for relinquishment of all claims against the individual and his companies and payment of $ 5.3 million to the individual in exchange for the stock in the three companies. The individual also agreed to sign an affidavit denying the Marcos family had any interest in his companies. The Philippine entity later sought to set aside the settlement, claiming the Marcos government compelled it to settle and that the agreements were illegal because they sought to prevent the individual from exposing the Marcoses' improper financial interests in the companies. On appeal, the Philippine entity sought to set aside a stipulated judgment on the ground of economic duress. The appellate court commented: "'As it has evolved to the present day, the economic duress doctrine is not limited by early statutory and judicial expressions requiring an unlawful act in the nature of a tort or a crime. Instead, the doctrine now may come into play upon the doing of a wrongful act which is sufficiently coercive to cause a reasonably prudent person faced with no reasonable alternative to succumb to the perpetrator's pressure. The assertion of a claim known to be false or a bad faith threat to breach a contract or to withhold a payment may constitute a wrongful act for purposes of the economic duress doctrine. ' ( Rich & Whillock, Inc. v. Ashton Development, Inc. (1984) 157 Cal. App. 3d 1154, 1158-1159, 204 Cal. Rptr. 86 . . . .)" ( Philippine Export & Foreign Loan Guarantee Corp. v. Chuidian, supra, 218 Cal. App. 3d at p. 1077.)