Francisco Culaba v. Court of Appeals

Summary

This civil case involved a collection dispute where the Culaba spouses, store owners, claimed they had fully paid their P24,910.00 debt to San Miguel Corporation by making payments to an alleged SMC supervisor. They presented four liquidation receipts as proof of payment. However, SMC proved these receipts were from a stolen booklet and published a notice of loss. All three court levels ruled against the Culabaes, applying agency law principles that require verification of an agent's authority before making payments. The Supreme Court emphasized that payment to an unauthorized person does not discharge contractual obligations under the Civil Code, and found the debtors negligent for failing to verify the collector's identity. The case establishes important precedent on the burden of proving agency authority and the consequences of negligent payment practices in commercial transactions.