DOCUMENTOS ACREDITATIVOS DE PAGO. FACTURAS.

Para poder acreditar un pago, o un impago, se han de reunir determinados requisitos de carácter imperativo, para que por ejemplo: pueda nacer un derecho de repetición en un proceso judicial, que pueda acreditarse un impago e iniciar un proceso de reclamación de la deuda, que pueda emplearse como documentos de descargo… las posibilidades son infinitas.
La jurisprudencia, considera que para acreditar un pago realizado, el documento acreditativo ha de encontrarse en un soporte adecuado:
– Adeudo a Cuenta.
– Resguardo de transferencia
– Letra
– Recibo de cobro
– “Recibí”
– Etc…
Pero ¿Qué pasa con las Facturas?
En lo que se refiere a las FACTURAS, son documentos privados emitidos por una sola de las partes y en principio carecen de toda eficacia probatoria. Por lo que, por sí solas, no constituyen prueba plena y eficaz, de modo que solamente cuando se ponen en relación con otros medios de prueba resultan eficaces como documento acreditativo de pago. (Sentencia de la Audiencia Provincial de Pontevedra, sección 6ª, sentencia de 17 enero de 2011)
La posesión de facturas es un hecho que demuestra el importe a reclamar, pero NO constituyen prueba del pago de dicho importe. Por lo que si no están avaladas por alguno de los soportes enumerados al principio de la publicación NO PRODUCEN EFECTOS DE PAGO, aunque estén firmadas por el acreedor y en posesión del deudor, no probaran el pago.
Así pues, la factura ha de ir acompañada del pertinente “recibí” o expresión análoga firmada por el acreedor que justifique haberse hecho el pago. Mientras no sea así, la posesión de la factura por el deudor seguirá siendo un hecho que puede provocar la reclamación de la deuda, ya que no acredita el pago. (Sentencia nº 634/2006 de Audiencia Provincial – Madrid, Sección 14ª, de 16 de Octubre 2006)
¿Nunca acredita el pago?
Aunque no se les reconozca como prueba plena de pago, no las priva de valor probatorio.
Si una parte niega la autenticidad de una factura, la parte contraria puede utilizar cuantos medios de prueba estime adecuados para acreditar su autenticidad, por lo que el tribunal apreciará globalmente las pruebas aportadas y determinará su veracidad. (Sentencia TS de 27 de noviembre de 2000)
De modo que, en base a los principios de buena fe y seguridad en el tráfico mercantil, junto con otras pruebas, que pueden ser simplemente indiciarias (por ejemplo, las que se deduzcan de la simple falta de prueba por su parte), pueden llevar a lograr una total eficacia probatoria. (SAP Zaragoza de 9 de diciembre de 2010).

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