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Royal Cargo Corporation v. DFS Sports Unlimited, Inc. G.R. No. 158621 Dec.

10, 2008 Facts: In October 1993, respondent DFS Sports Unlimited engaged the services of petitioner Royal Cargo Corp., an international freight forwarder. From April to July 1994, petitioner rendered its trucking, brokerage, storage and other services to the respondent in line with the latters importation business. As a consequence, petitioner incurred expenses from the services it rendered. Even upon petitioners demands, respondent refused to pay the expenses. Petitioner filed a complaint against the respondent. During the trial, petitioner presented several carbon copies of invoices to prove respondents indebtedness. Meanwhile, respondent presented the original copies of those invoices submitted by the petitioner for the purpose of proving its payment. Issues: a) Whether or not the burden of evidence lies with the debtor to prove that payment has been made; and b) Whether or not mere presentation of the original invoices by the debtor sufficiently proves payment of its debt. Held: On the first issue, the settled rule is that the one who pleads payment has the burden of proving it. The Supreme Court ruled that even where the creditor alleges non-payment, the general rule is that the burden of proof rests on the debtor to prove his payment, rather on the creditor to prove nonpayment. On the second issue, the Court ruled that original invoices are not sufficient to prove payment nor does it raise a presumption that respondent had indeed discharged its obligation to petitioner. An invoice is different from a receipt, which is an acknowledgment of the fact of payment between two parties. An invoice is simply a list containing the items, together with prices and charges. It is a mere detailed statement of the nature, quantity and cost of the things invoiced. Hence, an invoice may not be considered evidence of payment. Respondents defense of payment still needs to be supported by other evidence such as official receipts or testimony of the employee who paid, to prove it had indeed paid its obligation.