Feliciana Bantug v. Ambrosio del Rosario

Summary

This 1908 Supreme Court case involves a debt collection suit where plaintiff-administratrix Feliciana Bantug sought payment of P1,440 loaned by her deceased husband Santiago de Guzman to defendant Ambrosio del Rosario in 1893. The defendant claimed overpayment through various deliveries of goods and money totaling more than the debt. The trial court found only P317 worth of paddy delivery proven, reducing the debt to P1,123. The Supreme Court affirmed, applying Civil Code provisions on extinguishment of obligations and emphasizing that the creditor's possession of the debt document creates a legal presumption of non-payment. The Court held that the burden of proving payment rests on the debtor, and insufficient evidence was presented to establish the alleged payments. The case demonstrates early Philippine jurisprudence on burden of proof in debt collection cases and the application of Spanish Civil Code provisions on obligations.