Petitioner
Cesar L. Abueg
Respondent
Juliana Silva
Citation
G.R. No. 255380
Court
Supreme Court
Division
Second Division
Decided
May 10, 2021

Summary

This case involves a loan dispute where Silva sued Abueg for P87,000.00 in a small claims case. Abueg claimed full payment through rental payments and cited the presumption under Article 1176 of the Civil Code. The MTCC ruled for Silva, and Abueg's subsequent certiorari petitions were dismissed by higher courts. The Supreme Court denied the petition, holding that Abueg failed to prove payment and that the presumption he invoked did not apply. The Court emphasized that certiorari corrects only jurisdictional errors, not factual findings, and affirmed the burden of proof on defendants to establish payment. The case clarifies the scope of certiorari in small claims cases and reinforces principles of burden of proof in debt collection matters.

Statutes applied

By Intellegal Editorial Board · May 10, 2021

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