The Chinese Chamber of Commerce v. Pua Te Ching

Summary

The Chinese Chamber of Commerce sued on a P3,500 promissory note signed by multiple defendants including Pua Te Ching. When defendants filed only a general denial without specifically denying execution under oath, the Supreme Court held this constituted admission under Section 103 of the Code of Procedure, establishing a prima facie case. The Court rejected defendants' claimed payment through note substitution, finding plaintiff had refused such arrangement. Applying Article 1108 of the Civil Code and estoppel principles, the Court awarded plaintiff P3,284 (original amount less P216 partial payment) plus 12% interest, rejecting defendants' challenge to plaintiff's lending authority since they had accepted the money and contracted with plaintiff as a corporation.