GR 158621; (December, 2008) (Digest)
G.R. No. 158621 December 10, 2008
ROYAL CARGO CORPORATION, petitioner, vs. DFS SPORTS UNLIMITED, INC., respondent.
FACTS
Petitioner Royal Cargo Corporation, an international freight forwarder, filed a Complaint for Collection of Sum of Money against respondent DFS Sports Unlimited, Inc., a duty-free importer and seller of sporting goods. Petitioner sought to recover P248,449.63 for various trucking, brokerage, storage, and other services rendered to respondent between April and July 1994. In its Answer, respondent denied engaging petitioner’s services except for a single transaction in May 1994 and filed a counterclaim for damages, alleging petitioner’s gross negligence led to the seizure and loss of its imported goods. During trial, petitioner presented 34 carbon copies of invoices (Exhibits “A” to “A-33”) to prove the indebtedness. Respondent presented 28 original copies of those same invoices, claiming their possession proved payment. The Regional Trial Court dismissed both the complaint and counterclaim. The Court of Appeals affirmed the dismissal. Petitioner filed the present petition, arguing the CA erred in placing the burden of proof on the creditor and in ruling that the mere presentation of original invoices sufficiently proves payment.
ISSUE
1. Whether the burden of evidence lies with the debtor to prove that payment has been made.
2. Whether the mere presentation by the debtor of original invoices alone sufficiently proves payment of its debt.
3. Whether an invoice is deemed a credit instrument which, upon presentation by the debtor, raises the disputable presumption of payment under Rule 131, Section 3(h) of the Rules of Court.
RULING
1. Yes, the burden of evidence lies with the debtor to prove payment. The settled rule is that one who pleads payment has the burden of proving it. The onus rests on the debtor to prove with legal certainty that the obligation has been discharged.
2. No, the mere presentation of original invoices is not sufficient proof of payment. An invoice is not a credit instrument but merely a detailed statement of the nature, quantity, and cost of the items delivered or services rendered. It is a commercial document detailing a transaction, not an evidence of indebtedness or a proof of payment. Possession of the original invoice by the debtor does not, by itself, give rise to a presumption of payment.
3. No, an invoice is not a credit instrument for purposes of raising the disputable presumption of payment under Rule 131, Section 3(h). The presumption that an obligation delivered to the debtor has been paid applies to instruments of credit, such as promissory notes, bonds, and other securities for the payment of money. An invoice does not fall within this category. The Court found that the respondent failed to substantiate its claim of payment with clear and convincing evidence. The presentation of the original invoices, without more, did not overcome the petitioner’s evidence of non-payment. The Court reversed the decisions of the lower courts and entered judgment in favor of petitioner, ordering respondent to pay the principal amount with legal interest.