Que Yong Keng v. Rafael Tan Quico

Summary

Plaintiff sued defendant for P1,785 claiming various money deliveries and collection of a bill of exchange in China. The Court of First Instance awarded P300 based on the bill of exchange. The Supreme Court reversed, applying Civil Code Article 1280's evidence requirements and finding that the bill of exchange transaction was complete when plaintiff received P300 from defendant in exchange for the bill, and defendant properly collected it in Amoy. Since the exchange was completed, no additional obligation existed. The Court also affirmed the denial of defendant's P450 counterclaim due to insufficient evidence, demonstrating strict application of Civil Code proof requirements in contractual disputes.