Culaba v CA

G.R. No. 125862 April 15, 2004

Art. 1240 – Payment shall be made to person in whose favor obligation has been constituted.

Facts:

·          The spouses Francisco and Demetria Culaba were the owners and proprietors of the Culaba Store and were engaged in the sale and distribution of San Miguel Corporation’s (SMC) beer products.

·          SMC sold beer products on credit to the Culaba.

·           The Culaba spouses made a partial payment.

·          They failed to pay despite repeated demands. Hence, SMC filed an action for collection of a sum of money against them.

·          In their defense, Culaba claimed that they had already paid the SMC in full on four separate occasions to an SMC supervisor who issued genuine SMC liquidation receipts.

·          But SMC countered that the issued LR were part of the lost booklet receipts as evidenced by publisher’s affidavit that SMC duly warned the public about it through the Notice of Loss.

Issue:

WoN the payments that the petitioners claimed they made were the payments that discharged their obligation to the respondent.

Held:

            No, the Court holds that the payments claimed by the Culaba are not the payments that extinguishes an obligation pursuant to Article 1240 of the Civil Code.

            Under the said law, payment shall be made to the person in whose favor the obligation has been constituted, or his successor-in-interest, or any person authorized to receive it.

In this case, the payments were purportedly made to a "supervisor" of the private respondent, who was clad in an SMC uniform and drove an SMC van. He appeared to be authorized to accept payments. Unfortunately, Caluba did not ascertain the identity and authority of the said supervisor, nor did he ask to be shown any identification to prove that the latter was, indeed, an SMC supervisor. The petitioners relied solely on the man’s representation that he was collecting payments for SMC. Thus, the payments the petitioners claimed they made were not the payments that discharged their obligation to the private respondent.

           Hence, the instant petition is hereby DENIED.