- Petitioner
- US
- Respondent
- Chua
- Citation
- G.R. No. 13708
- Court
- Supreme Court
- Division
- En Banc
- Ponente
- Malcolm, J.
- Decided
- January 29, 1919
Summary
The Supreme Court affirmed the criminal conviction of Francisco Constantino Tan Quingco Chua for usury under Act No. 2655. The case involved a debt that grew from P100 in 1911 to P684.20 by 1916 through excessive interest charges. The defendant attempted to disguise the usurious transaction through a pacto de retro sale document, but the Court found this to be a sham to evade usury laws. The Court established that parol evidence is admissible to prove that apparently legal documents are actually devices to cover usury, and that the law will not permit usurious loans to hide behind legal forms. The decision emphasized that corrupt intent is essential for usury convictions and that courts must look beyond the form to the substance of transactions to prevent circumvention of anti-usury legislation.