Pacific Commercial Company v. Mauricia Sotto

Summary

Pacific Commercial Company sold merchandise to La Fortuna Bakery owned by Claro Ong, leaving a balance of P2,103.75. After Ong sold the bakery twice (buyers assuming liabilities) and died, Pacific Commercial claimed against his estate. The Supreme Court affirmed that no novation occurred despite subsequent buyers making payments, as the creditor never consented to substitution of debtors under Article 1205 of the Civil Code. The Court emphasized that novation is never presumed and requires explicit creditor consent. The estate remained liable for the original debt, establishing important precedent on commercial debt obligations and novation requirements in business transfers.