P. P. Angel Ortiz v. The Chinaman Felix Melliza (Alias Pinga)

Summary

This debt collection case established important burden of proof principles in Philippine civil law. Angel Ortiz sued to collect P4,037.82 from Felix Melliza after purchasing accounts from 'Viuda e Hijos de F. Suarez.' The Supreme Court modified the trial court's judgment, reducing the award to P3,647.22 based solely on defendant's own admission recorded in his Chinese-character book. The Court emphasized that mere presentation of unaccepted balance sheets is insufficient proof of debt, and that the burden lies on the creditor to prove the obligation's existence and amount. The decision reinforced Article 1214 of the Civil Code requiring creditors to prove their claims with competent evidence.