Even where the courts merely recite from the provisions of Article 312 of the Code of Practice, or later Article 1702 of the Code of Civil Procedure, that "an affidavit of correctness shall be prima facie proof," a review of the cases reveals a statement of account or invoice in each evidencing the basis of the demand. See e.g., Weiss v. Mayfield, 178 So. 511, 512 (Ct.App. Orleans, 1938); Goldberg v. Borenstein, 59 So.2d 172, 173-74 (Ct.App. Orleans 1952); Merchants Adjustment Bureau v. Malta, 102 So.2d 781, 782-83 (La.App. 2d Cir. 1958); King v. Calhoun, 107 So.2d 535, 536 (La.App. 2d Cir. 1958); Colonial Products Co. v. Park Place Homes, Inc., 282 So.2d 574, 575 (La.App. 4th Cir. 1973); Roberts v. Paciera, 411 So.2d 650, 651 (La.App. 4th Cir. 1982); Lafitte Sash Door Co. v. Robert Bros. Homes, Inc., 411 So.2d 1120, 1121-22 (La.App. 4th Cir. 1982). Some cases are more explicit as to the proof necessary to confirm a default judgment on an open account.
In this case, the trial court having stated, "plaintiff making due proof of claim herein," it must be presumed that the Court had sufficient evidence to justify the judgment appealed from herein. In King v. Calhoun, La. App., 107 So.2d 535, the Court said: "Our jurisprudence holds that where, as in the instant case judgment recites 'on producing due proof in support of the plaintiff's demands * * * and the law and evidence being in favor of plaintiff' such a statement is equivalent to saying that proof of the correctness of plaintiff's demand had been adduced and this is all that is required to confirm a default.
We therefore affirm the judgment. A default judgment is presumed to have been rendered upon the necessary evidence and in accordance with law unless the record shows the contrary, even though there is no note of evidence or (in lieu) no formal narrative of facts. First Nat. Bank of Arcadia v. Sam M. Richardson Co., 163 La. 15, 111 So. 475; Associates Discount Corp. v. Downs, La. App. 1 Cir., 162 So.2d 758, 8 A.L.R.3d 1066; King v. Calhoun, La. App. 2 Cir., 107 So.2d 535. The costs of the appeal are to be paid by the defendant-appellant.