- Petitioner
- Good Earth Emporium Inc.
- Respondent
- Honorable Court of Appeals
- Citation
- G.R. No. 82797
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Paras, J.
- Decided
- February 27, 1991
Summary
This case involves a lease dispute where Good Earth Emporium defaulted on rental payments to Roces-Reyes Realty Inc., resulting in an ejectment case and judgment for P1,560,000.00. Petitioners claimed satisfaction of judgment debt through P2 million in payments to individual Roces brothers. The Supreme Court affirmed the Court of Appeals' ruling that payments made to individual stockholders cannot satisfy corporate debt due to separate juridical personality. The Court emphasized that under Article 1240 of the Civil Code, payment must be made to the proper creditor - the corporation, not its individual officers or stockholders. The burden of proving payment satisfaction rests on the debtor, which petitioners failed to discharge with convincing evidence. The case reinforces fundamental principles of corporate law regarding separate juridical personality and proper payment of obligations.