FACTS:
Esteban Lopez drew a document on February 6, 1906, requesting Inchausti & Co. to pay “to the order of Chinaman Yap-Soco at six days’ sight the sum of eight hundred pesos on account of this hacienda.” Inchausti & Co. accepted the document on February 7, 1906, making it “Payable on February 13, 1906.” However, on February 13, 1906, Inchausti & Co. stopped payment upon receiving advice from Lopez, who stated he had not received the P800 from Yap-Soco and that Yap-Soco’s properties had been burned. A blank signature “M.C. Yap-Soco” appeared on one side of the document. Go Chioco filed a complaint, claiming ownership of the document by virtue of this blank indorsement, and sought payment of P800 from Inchausti & Co. Inchausti & Co. denied the validity of the indorsement and the transfer of ownership. The trial court ruled in favor of Go Chioco, prompting Inchausti & Co. to appeal.

ISSUE:
Whether the undated blank indorsement by Yap-Soco was sufficient to transfer ownership of the document to Go Chioco.

RULING:
No. The Supreme Court, in its decision dated March 23, 1908, reversed the trial court’s judgment. The Court reiterated the doctrine established in Warner, Barnes & Co. vs. E. Diaz & Co. and International Banking Corporation vs. Montagne, holding that “if the date is omitted in the indorsement, the ownership of the draft shall not be transferred, and it shall be understood as simply a commission for collection.” Therefore, the undated blank indorsement by Yap-Soco did not transfer ownership of the document to Go Chioco. The Court also noted that the document itself was more akin to a promissory note under Article 450 of the Code of Commerce rather than a bill of exchange, but the decisive factor was the invalidity of the undated indorsement for transferring ownership.