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	GR No. 171750 2012-01-25	UNITED PULP v. ACROPOLIS CENTRAL GUARANTY CORPORATION MENDOZA, J.
This Court has consistently held that the filing of a complaint constitutes a judicial demand.[32] Accordingly, the filing by UPPC of the Motion to Order Surety to Pay Amount of Counter-Bond was already a demand upon Acropolis, as surety, for the payment of the amount due, pursuant to the terms of the bond. In said bond, Acropolis bound itself in the sum of ?42,844,353.14 to secure the payment of any judgment that UPPC might recover against Unibox and Ortega.[33]
	GR No. 147950 2003-12-11	CALIFORNIA BUS LINES v. STATE INVESTMENT HOUSE QUISUMBING, J.
The necessity to prove the foregoing by clear and convincing evidence is accentuated where the obligation of the debtor invoking the defense of novation has already matured.[54]