Multi-International Business vs Ruel Martinez (PAYMENT)

FACTS:

Herein respondent Ruel Martinez was the Operations manager of the Petitioner Company from the last
quarter of year 1990 up until January 22, 1999.

In June 1994 – Martinez applied and was granted a car loan by petitioner company amounting to 648,288
pesos. Parties agreed that the loan obligation would be payable through the bonuses and commissions if
any and in case of termination of respondent for any cause before the end of the term of the loan
obligation, remaining unpaid balance would immediately be due and demandable without the need of
demand.

Jan 22, 1999 – petitioner terminated respondent and immediately demanding that Martinez pay the
outstanding loan of 418,012.75, despite this respondent failed to pay.

July 12, 1999- Petitioner through RTC of Makati filed complaint praying that Martinez be ordered to pay
remaining unpaid balance, atty’s fees, exemplary damages and costs for the suit. During trial Respondent
Martinez presented in court a certification dated Sept 10, 1996 signed by President of the petitioner
company Helen Dy. Stated in the certification is that Martinez had already paid to the amount of 337,650
pesos. RTC ruled in favor of petitioner stating that Martinez was not able to establish authenticity of the
certification and that he was not able to prove payment.

Respondent appealed to CA and trial court decision was reversed. CA found credence on the following.
-Certification (presented by Matinez)
-Deduction (the deductions made on respondent’s payslips to pay the loan obligation)
- Petitioner’s admission of respondent’s payment in installment.
-Helen Dy also neither confirmed nor denied the authenticity of the certification she signed.

ISSUE: WON respondent Martinez had already fulfilled his OBLIGATION with the petitioner company?

HELD:

COURT first re-evaluated facts of the case because of the conflicting finding of CA and RTC. They later
on found that certification dated sept 10, 1996 signed by Helen Dy that was presented by Martinez was
authentic and that it was an admissible evidence for payment.

*COURT ruled that obligation was not fulfilled. SC stated that it has been established that burden of proof
always lies upon the one who pleads payment. Even though creditor alleges non-payment burden to
proof payment still lies upon debtor.

*receipt is the best evidence of payment. In this case other than the certification dated Sept 10, 1996
signed by Helen Dy, there were no other records that could show or prove his payments on the loan
obligation and when asked regarding of the allegation he made that deductions made on his salaries. He
said that he could not give an estimate amount since he did not know. Later he admitted that he only
assumed that deductions were made on his salaries because there were no such deductions that were
showed in his payslips.

Since it was proved that he was only able to pay up to 337,650 pesos, he was ordered by the court to
pay the remaining balance of 310,638 pesos plus 6% interest per annum.