Facts:

In the case of Ang Quian Cieg et al. vs. Juan Te Chico et al., G.R. No. 4766, decided on January 19, 1909, the plaintiffs, Ang Quian Cieg and others, sought to recover a total of approximately P9,156 represented by eight promissory notes signed by Te Quim Jua, who was the manager of the partnership Sam Jap Jim & Co. based in Manila. The partnership had other related cases, including those of Margarita Mendoza and Trinidad Jurado Te Quim Jua, which were concurrently considered in the lower courts. The agreement was made during the trial that all evidence presented in these cases could be applied across them.

The promissory notes in question were dated and varied in amounts, with some notes issued to Margarita Mendoza and others to Jua Qui. Te Quim Jua, the manager who signed these promissory notes, had authority to transact on behalf of the partnership, including borrowing money. However, the defendants, Juan Te Chico and Cu Ung Jeng, argued that the claims arising from the n

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Facts:

Consolidation of Related Cases

• The case involves interrelated actions consolidated by agreement in the Court of First Instance.
• The actions include:
• Ang Seng Quen et al. vs. Juan Te Chico et al. (G.R. No. 4765)
• Margarita Mendoza vs. Juan Te Chico (G.R. No. 4767)
• Trinidad Jurado Te Quim Jua vs. Juan Te Chico et al. (G.R. No. 4768)
• It was agreed among these cases that evidence presented in any one case could be considered in all, so far as its relevance extended.

Subject Matter and Claims

• In the present case, the plaintiffs seek recovery of amounts represented by promissory notes.
• Eight promissory notes, signed by Te Quim Jua as manager in the Manila branch of the defendant partnership Sam Jap Jim & Co., amounting to approximately P9,156, are central to the action.
• In the Margarita Mendoza case, the claim is based on five promissory notes also signed by Te Quim Jua.
• The notes vary in amounts and maturity periods and are listed with specific dates and amounts (e.g., from P3,000 to P5,000 with differing term lengths).

Nature and Authenticity of the Promissory Notes

• Testimonies regarding the issuance of the notes:
• Plaintiff witnesses stated that the notes were issued at different times corresponding to their dates.
• Claro Reyes testified that all notes were made on a typewriter on Catalan paper from his office.
• Defendants' contention:
• They argued that internal evidence from the notes—such as consistent typewritten lettering, blurred letters, and watermark indentations—demonstrated that notes in each respective suit were actually executed at a single time.
• Specific exhibits (Exhibit B, Exhibit D in the Margarita Mendoza case and Exhibit E in the present case) were highlighted to show differences in the blurred letters and other intrinsic features.

Transactional Background and Financial Operations

• Role of key individuals:
• Te Quim Jua, the manager of the Manila branch, admitted receiving funds and utilizing them in the business of the defendant company.
• Juan Te Chico, general manager and partner, resided in Iloilo but also operated in Manila; his period of absence and subsequent return is significant.
• Ong Bong Po, acting as Te Chico’s representative in Iloilo during his absence, frequently drew drafts on the Manila branch directing large sums.
• Business operations of Sam Jap Jim & Co.:
• The company was engaged in the purchase and shipment of sinamay, jusi, and other merchandise between Iloilo and Manila.
• The financial transactions, including the borrowing and subsequent use of funds, were integral to the company’s business.
• Evidence such as letters between Ong Bong Po and Te Quim Jua confirmed that money was indeed borrowed to finance transactions, including drafts totaling more than P40,000.

Additional Evidentiary Considerations

• Documentary evidences and their peculiarities:
• The notes, predominantly in Spanish, raised interpretative challenges as some plaintiff witnesses could neither read nor fully understand Spanish.
• It is suggested that the original memoranda or records of the transactions might have been replaced by the promissory notes after all transactions were completed.
• Testimonies regarding the handling of funds:
• There is evidence that the money advanced by the plaintiffs was indeed paid to and utilized by Te Quim Jua in the business of the defendant company.
• Testimony from Juan Te Chico himself confirmed that he was aware of the loans, with corroborative evidence from other witnesses stating that he participated in counting the money received.

Issue:

Authenticity and Execution Timing of the Promissory Notes

• Were the promissory notes issued on their purported dates, or were they fabricated at a single time?
• Does the internal evidence (typewritten letters, blurred characters, watermark indentations) conclusively demonstrate simultaneous execution?

Validity of the Evidentiary Basis for the Loans

• Is there sufficient evidence to prove that the money represented by the promissory notes was actually paid to Te Quim Jua?
• Does the testimony of various witnesses, including the admissions by Te Quim Jua, establish a clear chain of borrowing and use of the funds by the defendant company?

Liability of the Defendant Partnership and Its Members

• Should the defendant partnership, as well as Juan Te Chico as general manager, be held liable to repay the money advanced by the plaintiffs?
• How does the interrelation of the various cases affect the allocation of liability among the partners, especially between Juan Te Chico and Cu Ung Jeng?

Effect of Discrepant Testimonies and Documentary Irregularities

• To what extent do the contradictory testimonies regarding the issuance of the notes and the internal documentary features impact the court’s assessment of the case?
• Is the alleged conspiracy between plaintiffs and Te Quim Jua to defraud the defendant company supported by sufficient evidence?

Ruling:

• (Subscriber-Only)

Ratio:

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Doctrine:

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