GR 82797; (February, 1991) (Digest)
G.R. No. 82797 ; February 27, 1991
Good Earth Emporium Inc., and Lim Ka Ping, petitioners, vs. Honorable Court of Appeals and Roces-Reyes Realty Inc., respondents.
FACTS
Roces-Reyes Realty Inc. (Roces) filed an ejectment case against Good Earth Emporium Inc. (GEE) for default in rental payments. The Metropolitan Trial Court (MTC) rendered a judgment on the pleadings, ordering GEE to vacate the premises and pay accrued rentals. GEE initially appealed but later withdrew its appeal, leading to the issuance of an alias writ of execution by the MTC. GEE moved to quash the writ, claiming the judgment debt had been fully satisfied through a P1 million receipt (Exhibit “1”) and a P1 million pacto de retro sale (Exhibit “2”), totaling P2 million.
The MTC denied the motion to quash. On appeal, the Regional Trial Court (RTC) reversed the MTC, finding the P2 million constituted full payment and quashed the writ. Roces appealed to the Court of Appeals (CA), which reversed the RTC and reinstated the MTC’s resolution, holding that the documents did not establish payment of the specific judgment obligation.
ISSUE
Whether the alias writ of execution should be quashed on the ground that the judgment debt had been fully satisfied by the petitioners.
RULING
The Supreme Court denied the petition and affirmed the CA decision. The legal logic centers on the burden of proof regarding payment extinguishing an obligation. The Court emphasized that the existence of the debt (the judgment for unpaid rentals) was conclusively established. Therefore, the burden shifted to the debtor, GEE, to prove with clear and convincing evidence that this debt had been extinguished by payment. The Court scrutinized Exhibits “1” and “2” and found they contained no indication, notation, or reference whatsoever that the P2 million was intended to pay the specific judgment obligation in favor of Roces. The fact that the total amount (P2M) exceeded the judgment sum (P1.56M) further undermined the claim, as the proffered explanation for the excess—interest and advance rent—was unsupported by any evidence in the records or the motion to quash. Since GEE failed to discharge its burden of proof, the quashal of the writ was unjustified. The appellate court correctly refused to go beyond the unambiguous documents absent compelling evidence, finding no grave abuse of discretion in its factual determination.