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	GR No. 180144 2014-09-24	LEONARDO BOGNOT v. RRI LENDING CORPORATION BRION, J.
In Guinsatao v. Court of Appeals,[31] this Court pointed out that while a promissory note is evidence of an indebtedness, it is not the only evidence, for the existence of the obligation can be proven by other documentary evidence such as a written memorandum signed by the parties.