Bibiana Isaac v. H. W. Bray

Summary

This 1915 Supreme Court case involved the collection of a 4,000 Spanish dollar debt evidenced by a promissory note. The plaintiffs, heirs of Manuel Abella, sued defendants H.W. Bray and Manuel Pardo for payment of a note acknowledging debt assumed from hacienda improvements. The Court of First Instance dismissed the case, finding the obligation satisfied. However, the Supreme Court reversed, holding that defendants failed to prove payment despite vague claims of goods delivery. The Court applied the principle that creditor's possession of an acknowledged promissory note proves non-payment unless the debtor demonstrates otherwise. The obligation was ruled several rather than joint, and being non-commercial in nature, was subject to the Civil Code's 15-year prescription period, which had not elapsed. The Court ordered defendants to pay severally with 12% annual interest from 1896.