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NOEMI M. CORONEL v. ENCARNACION C. CAPATI

This case has been cited 3 times or more.

	GR No. 195640 2012-12-04	SUGAR REGULATORY ADMINISTRATION v. ENCARNACION B. TORMON PERALTA, J.
Petitioner withheld 25% of private respondents' incentive and terminal leave benefits because of their failure to present evidence of refund of the amounts of retirement and incentive benefits earlier received from PHILSUGIN/SQA. On the other hand, private respondents claim that they had already refunded these benefits through salary deduction, therefore, they are entitled to the payment of the amounts withheld by petitioner. The burden of proof is on private respondents to prove such refund. One who pleads payment has the burden of proving it.[14] Even where the creditor alleges non-payment, the general rule is that the onus rests on the debtor to prove payment, rather than on the creditor to prove non-payment.[15] The debtor has the burden of showing with legal certainty that the obligation has been discharged by payment.[16]
	GR No. 158621 2008-12-10	ROYAL CARGO CORPORATION v. DFS SPORTS UNLIMITED AUSTRIA-MARTINEZ, J.
As to the first issue raised, the settled rule is that one who pleads payment has the burden of proving it.[19] Even where the creditor alleges non-payment, the general rule is that the onus rests on the debtor to prove payment, rather than on the creditor to prove non-payment.[20] The debtor has the burden of showing with legal certainty that the obligation has been discharged by payment.[21] Where the debtor introduces some evidence of payment, the burden of going forward with the evidence - as distinct from the general burden of proof - shifts to the creditor, who is then under a duty of producing some evidence to show non-payment.[22]
	GR NO. 164159 2007-07-17	HONORIO C. BULOS v. KOJI YASUMA CHICO-NAZARIO, J.
When the existence of a debt is fully established by the evidence contained in the record, the burden of proving that it has been extinguished by payment devolves upon the debtor who offers such defense. The debtor has the burden of showing with legal certainty that the obligation has been discharged by payment.[21] In the present case, the petitioner failed to prove that indeed, his liability to pay the remaining balance of his obligation with the respondent had been extinguished by his offer to transfer to respondent his shares of stocks in the Rural Bank of Parañaque.