Who has the burden of proving that a negotiable instrument was issued for a consideration?

The drawer of a check, not the payee, has the burden of proof to show that the instrument was issued without sufficient consideration. Since a negotiable instrument is presumed to have been issued for a valuable consideration, the mere presentation of a dishonored instrument in evidence entitles the holder to recover from the drawer even if the payee did not establish the accountability of the drawer. (Travel‐On v. CA, G.R. No. L‐ 56169, June 26, 1992)