- Petitioner
- Tan Shuy
- Respondent
- Spouses Guillermo Maulawin
- Citation
- G.R. No. 190375
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Sereno, J.
- Decided
- February 8, 2012
Summary
This Supreme Court case involved a civil dispute over loan repayment between copra businessman Tan Shuy and farmer Guillermo Maulawin. In 1997, Tan Shuy loaned P420,000 to Maulawin with an agreement to sell copra to the lender. From 1998-1999, Maulawin delivered copra worth P420,537.68 and claimed the proceeds were applied as loan payments, evidenced by pesadas (delivery receipts) without cash payment notations. The trial court and appellate court found this constituted partial dation in payment under Civil Code Article 1245, but excluded corn deliveries worth P41,585.25 since only copra proceeds were agreed upon for loan application. The Supreme Court affirmed, recognizing P378,952.43 in creditable copra payments, leaving a loan balance of P41,047.57. The decision established important precedent on dation in payment and authentication of private commercial documents in agricultural business transactions.