Case Digest (G.R. No. 40457) Core Legal Reasoning Model
Facts:
The case involves Mobil Oil Philippines, Inc. as the petitioner, and Geminiano F. Yabut and Agueda Enriquez Yabut, among others, as respondents. The events took place in the Court of First Instance of Rizal, Branch VI, Pasig. On November 8, 1972, petitioner Mobil Oil filed a complaint against the partnership La Mallorca and its general partners, including the private respondents. The complaint was for collection of a sum of money due to gasoline purchased on credit but unpaid, damages, and attorney’s fees. On December 22, 1972, Mobil Oil filed an amended complaint to include the heirs of deceased partners as defendants.
During a hearing on April 1, 1974, after Mobil Oil presented its evidence, the parties agreed to submit the case for decision based on the evidence on record, excluding past interest amounting to ₱150,000.00, and awarding only nominal attorney's fees. A judgment favorable to Mobil Oil was rendered on July 25, 1974. Subsequently, Geminiano and Agueda Yabut fi
Case Digest (G.R. No. 40457) Expanded Legal Reasoning Model
Facts:
- Parties and Nature of the Case
- Petitioner Mobil Oil Philippines, Inc. filed a complaint on November 8, 1972, against the partnership La Mallorca and its general partners, including respondents Geminiano F. Yabut and Agueda Enriquez Yabut, for collection of money owed for gasoline purchased on credit, damages, and attorney’s fees.
- On December 22, 1972, petitioner amended the complaint to include the heirs of deceased partners as defendants, with leave of court.
- Proceedings and Agreements
- During the hearing on April 1, 1974, after petitioner presented evidence, parties agreed to submit the case for decision on the basis of petitioner’s evidence but with these conditions:
- Exclusion of past interest amounting to ₱150,000.00.
- Award of nominal attorney’s fees rather than a stipulated percentage.
- The Court rendered a Decision on July 25, 1974, in favor of petitioner, ordering La Mallorca Partnership and the partners jointly and severally to pay sums including damages and attorney’s fees.
- Petition for Modification and Orders Declaring Nullity
- Private respondents filed a Petition to Modify Decision or for Reconsideration relying on these grounds:
- No agreement on attorney’s fees award.
- Miguel Enriquez was not a general partner and thus could not bind the partnership.
- Geminiano Yabut had ceased to be partner and president as of September 14, 1972.
- The Court of First Instance, Branch VI, Pasig, on November 20, 1974, issued an Order declaring the July 25, 1974 Decision null and void concerning private respondents for lack of evidence that their counsel was authorized to stipulate or compromise the case.
- Petitioner moved for reconsideration and clarification, and later, for a writ of execution and appointment of special sheriff; both motions were denied by the Court on February 20, 1975.
- Authority and Acts of Counsel
- Counsel for the parties had implied authority to waive presentation of evidence and agree on submission for decision on evidence presented.
- Such waivers included petitioner’s waiver of past interest and modified attorney’s fees and defendants’ waiver of presenting further evidence.
- No objection or contestation of the counsel’s authority or the stipulation was made by respondents in the records.
- Partnership and Liability Issues
- Miguel Enriquez became a general partner by operation of the partnership agreement as an heir of a deceased partner.
- Geminiano Yabut’s withdrawal from partnership after incurring the debt did not absolve liability as a partner in a partnership obligation.
- Active participation in partnership business is not required for liability or entitlement to profits in partnership law.
Issues:
- Whether the Court of First Instance gravely abused its discretion when it declared the July 25, 1974 Decision null and void for lack of evidence that the private respondents’ counsel was authorized to enter into stipulations or compromise and confessions of judgment.
- Whether the waiver by private respondents’ counsel of presentation of evidence and petitioner’s waiver on interest and attorney’s fees constituted a valid submission of case for decision or a compromise agreement.
- Whether Miguel Enriquez was a general partner with authority to bind the partnership and whether Geminiano Yabut was liable as a partner despite alleged withdrawal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)