- Petitioner
- Chua Chienco (Alias Tima)
- Respondent
- Angel Vargas
- Citation
- G.R. No. 4414
- Court
- Supreme Court En Banc
- Division
- En Banc
- Ponente
- Torres, J.
- Decided
- September 7, 1908
Summary
A debt collection case where Chinese merchant Chua Chienco sued Angel Vargas for P1,382.50 in unpaid loans evidenced by vales (promissory notes). Vargas acknowledged receiving the money but claimed payment through three P500 drafts drawn on a firm in Iloilo. The Supreme Court affirmed the trial court's judgment for plaintiff, holding that the debt was conclusively proven by acknowledged vales, while defendant failed to prove actual payment through the drafts. The Court established that acknowledged private documents constitute sufficient proof of debt under Civil Code Article 1225, and that the burden of proving payment lies with the debtor under Articles 1156 and 1214. This early 1908 decision demonstrates foundational principles of obligations and contracts law, particularly regarding burden of proof in debt collection cases and the evidentiary value of acknowledged commercial documents.