Case Summary (G.R. No. 4414)
Complaint and Preliminary Attachment
On July 22, 1904, the attorney for the plaintiff filed a complaint against Vargas, claiming total payments received by Vargas from Chienco amounted to 2,082.50 pesos. Vargas had only repaid 700 pesos, leaving an outstanding balance of 1,382.50 pesos. The plaintiff requested a preliminary attachment to secure Vargas's carabaos and cattle, fearing that Vargas might conceal or sell them to evade payment.
Defendant’s Demurrer and Amendments
In response to the initial complaint, Vargas filed a demurrer stating he was unfamiliar with Chienco (referred to as Sua Tico) and thus disputed his obligation. On August 14, 1904, the plaintiff's counsel sought to amend the complaint to correct the name from Sua Tico to Chua Tinco, which the court allowed. This amendment clarified the identity of the plaintiff and re-established the framework for the case.
Answer and Counterclaims
After acknowledging the amended name, Vargas responded that there indeed existed business transactions resulting in a debt of 700 pesos owed to the plaintiff. Vargas argued that he had further engaged in transactions, leading to the issuance of three drafts of 500 pesos each to offset the outstanding debt. He requested the return of the corresponding vales and sought damages for the preliminary attachment.
Evidence and Judicial Findings
The trial revealed numerous evidential documents, such as vales, which were recognized by both parties, proving the existence of the debt of 1,382 pesos. The record confirmed that Vargas had received funds from Chienco but failed to substantiate his claims regarding the drafts or demonstrate that he had settled the outstanding balance.
Legal Principles Applied
In reviewing the obligations under Articles 1156 and 1214 of the Civil Code, the burden of proof lay with the debtor (Vargas) to establish that the debt had been duly paid. The evidence definitively showed that the plaintiff had not received payment equivalent to the claimed debt, and the la
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Case Overview
- Date of Decision: September 07, 1908
- Court: Supreme Court of the Philippines
- Parties Involved:
- Plaintiff/Appellee: Chau Chienco (alias Tima)
- Defendant/Appellant: Angel Vargas
Procedural History
- On July 22, 1904, a complaint was filed by the attorney for Sua Tico in the Court of First Instance of Occidental Negros against Angel Vargas.
- The complaint sought to recover a total of 1,382.50 pesos, alleging that Vargas had received 2,082.50 pesos from the plaintiff but had only paid back 700 pesos.
- Vargas's attorney demurred to the complaint, claiming no business relationship existed between Vargas and the plaintiff.
- The court allowed an amendment to the complaint to correct the name of the plaintiff to Chua Tinco, alias Tima.
- On August 23, 1904, Vargas responded, acknowledging some transactions but contending he was owed money due to drafts drawn against a third party.
Key Allegations
- Plaintiff's Claims:
- Alleged that Vargas received a total of 2,082.50 pesos and only made partial repayments.
- Sought a prelimi