- Petitioner
- Santiago Tin Fian
- Respondent
- Pablo Tan
- Citation
- G.R. No. 4235
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Johnson, J.
- Decided
- September 15, 1909
Summary
This commercial dispute involved Santiago Tin Fian's claim against Pablo Tan for P608.33 representing goods sold and delivered during 1904-1905. Tin Fian also sought P500 damages for non-payment. The Court of First Instance of Leyte ruled in favor of Tin Fian for the principal amount with interest but denied damages. The Supreme Court affirmed, finding the preponderance of evidence supported the plaintiff's claims based on testimonial and documentary evidence including vales and book accounts. The Court denied the damages claim, applying Article 1108 of the Civil Code which limits damages for non-payment of monetary obligations to agreed or legal interest absent contractual stipulation. The decision established that commercial creditors cannot recover punitive damages without specific contractual provisions, emphasizing the Civil Code's restrictive approach to monetary obligation damages.