Short answer. Likely yes. Article 1176 says the receipt of the principal by the creditor without reservation as to interest gives rise to a presumption that the interest has been paid. So a clean principal receipt that is silent on interest works in your favour, though the lender can still overturn the presumption with contrary proof.
What the law says
The receipt of the principal by the creditor without reservation with respect to the interest, shall give rise to the presumption that said interest has been paid.
Civil Code, Article 1176 — Presumptions on Receipts. Read the full provision →
What the presumption actually says
Article 1176 gives you an evidentiary shortcut. When a creditor issues a receipt for the principal without reservation with respect to the interest, the law presumes the interest has been paid as well. The reasoning is practical: interest ordinarily falls due before the capital, so a lender who accepts the principal while staying silent on the interest is treated as having already collected it. You do not have to prove separately that you paid the interest — the receipt does that work for you, shifting the burden onto the lender to show that something remains owing.
It is a presumption, not a conclusion
The word to hold onto is presumption. This is a disputable presumption, not an irrebuttable rule. It stands only until the creditor produces convincing evidence that the interest was in fact not paid — a written reservation, a separate acknowledgment that interest remained outstanding, or an agreement that the payment applied to capital alone. If your lender expressly noted on the receipt that interest was still due, the presumption never arises in the first place. Silence is what triggers it; a clear reservation defeats it. Read the receipt carefully before relying on this provision.
The same logic for installments
The article carries a second, related presumption. The receipt of a later installment of a debt without reservation as to prior installments likewise raises the presumption that those earlier installments have been paid. If you owe by monthly installments and your creditor hands you a clean receipt for, say, the June payment without flagging any arrears, the law presumes March, April and May were settled too. Both presumptions rest on the same idea: a creditor who quietly takes a later or larger payment is presumed to have nothing earlier left outstanding against you.
What the rule does not do
Article 1176 settles who must prove what; it does not erase a debt that was genuinely never paid. Because the presumption can be overcome, keep your own proof — bank transfers, prior receipts, ledgers — rather than relying on the lender's silence alone. Nor does the provision fix the rate or legality of the interest; it assumes a valid interest obligation and only asks whether it was discharged. If the receipt itself contains a reservation, or the parties agreed the payment covered principal only, this presumption gives you nothing. Where money is at stake, insist on a receipt that says plainly what it covers.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Nunelon R. Marquez vs. Elisan Credit Corporation, G.R. No. 194642, April 6, 2015 — read the decision on LawPhil →
- Rizal Commercial Banking Corporation vs. Pedro P. Buenaventura, G.R. No. 176479, October 6, 2010 — read the decision on LawPhil →
- Carmelita Leaño, etc. vs. Court of Appeals, et al, G.R. No. 129018, November 15, 2001 — read the decision on LawPhil →