GR L 4717; (February, 1909) (Digest)
G.R. No. L-4717
RAFAEL O. RAMOS, administrator of the intestate estate of the spouses Jose Ramos Silva and Margarita Tanate, plaintiff-appellee, vs. TOMAS LEDESMA, defendant-appellant.
February 1, 1909 (Confirmation of judgment); February 17, 1909 (Basis of decision)
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FACTS:
Rafael O. Ramos, as administrator of the intestate estate of Jose Ramos Silva and Margarita Tanate, filed a complaint against Tomas Ledesma, seeking payment of P2,450.09 plus legal interest. This sum was allegedly owed by Ledesma to the deceased Jose Ramos, based on a private document (promissory note) dated May 13, 1902, due on March 15, 1903. The debt was guaranteed by a mortgage on Ledesma’s land.
Ledesma initially denied the allegations but later amended his answer. He admitted owing Jose Ramos a certain sum and giving a promissory note. However, he claimed to have paid P1,701.69 to the plaintiff on May 1, 1905, arguing that this payment constituted a novation of the original debt and that he should only be liable for the remaining balance.
At trial, Ledesma presented two key documents:
1. Promissory Note “D”: Dated June 29, 1900, for P1,701.69, payable to Martin Ramos (another administrator of the estate), secured by Ledesma’s land.
2. Receipt “A”: Dated May 1, 1905, signed by M. Ramos, acknowledging receipt of P1,701.69 from Ledesma. The receipt explicitly stated that this sum was paid “in settlement of his debt to my deceased brother D. Jose Ramos under guaranty to his land… according to a private document which I this day return to the interested party” (referring to Promissory Note D). It further stated: “with the exception of his titulo real and the promissory note for two thousand four hundred and fifty-nine pesos and sixty-nine cents, which are in the hands of Sr. Timoteo Gayco…”
The promissory note for P2,450.09 (referred to as “No. 1”), which was the subject of the complaint, remained in the possession of the creditor.
The lower court ruled in favor of the plaintiff, ordering Ledesma to pay the full P2,450.09 plus interest, finding no proof that the P1,701.69 payment was a partial payment of the debt claimed. Ledesma appealed, reiterating his claim of partial payment.
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ISSUE:
Whether the payment of P1,701.69 made by Tomas Ledesma, evidenced by Receipt A and the return of Promissory Note D, should be considered a partial payment of the P2,450.09 debt (Promissory Note No. 1) claimed by the plaintiff.
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RULING:
The Supreme Court affirmed the lower court’s judgment, holding that the defendant Tomas Ledesma must pay the full amount of P2,450.09 with legal interest.
The Court reasoned that the P1,701.69 payment, as evidenced by Receipt A, was a complete settlement of the debt specified in Promissory Note D. Receipt A explicitly stated that the payment was “in settlement of his debt… according to a private document which I this day return to the interested party,” clearly indicating that Promissory Note D (for P1,701.69) was the debt being satisfied and returned to Ledesma.
The Court found that the P1,701.69 debt (Promissory Note D) and the P2,450.09 debt (Promissory Note No. 1) were two distinct obligations. The fact that the same property might have served as security for both debts did not merge them into a single obligation or mean that the payment of one was a partial payment of the other.
Furthermore, the promissory note for P2,450.09 (Note No. 1), which was the subject of the lawsuit, remained in the creditor’s hands. According to Article 334, No. 8 of the Code of Civil Procedure (now Art. 1271 of the Civil Code), an obligation is only presumed to have been paid when the evidence of its existence has been returned to the debtor. The non-return of Promissory Note No. 1 indicated that the debt it represented had not been paid.
The Court emphasized that Article 1157 of the Civil Code states that “a debt shall only be considered as paid when the full amount of the thing has been delivered, or the prestation of which the obligation consisted has been made.” The payment of one distinct debt cannot be considered a partial payment of another distinct debt.