Case Digest (G.R. No. 144214) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On July 25, 1984, Luzviminda J. Villareal, Carmelito Jose and Jesus Jose established a partnership with a capital of ₱750,000 to operate “Aquarius Food House and Catering Services” in Makati City. Villareal was appointed general manager and Carmelito Jose, operations manager. On September 5, 1984, Donaldo Efren C. Ramirez was admitted as a partner upon a ₱250,000 capital infusion paid by his parents, Spouses Cesar G. Ramirez Jr. and Carmelita C. Ramirez. In January 1987, Jesus Jose withdrew and received a cash refund of ₱250,000. That same month, without notifying the Ramirez spouses, the remaining partners closed the restaurant due to high rent and stored the business furniture and equipment at the Ramirezes’ residence. On March 1, 1987, the Ramirezes notified the petitioners they no longer wished to continue the venture and accepted the offer to return their capital. After a second letter on October 13, 1987, complaining of asset deterioration and reiterating their request, pe Case Digest (G.R. No. 144214) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Formation and operation of the partnership
- On July 25, 1984, Luzviminda J. Villareal, Carmelito Jose and Jesus Jose formed a partnership with a P750,000 capital for the “Aquarius Food House and Catering Services.” Villareal was general manager; Carmelito Jose, operations manager.
- On September 5, 1984, Donaldo Efren C. Ramirez joined as partner with a P250,000 contribution paid by his parents, spouses Cesar G. Ramirez Jr. and Carmelita C. Ramirez.
- Events leading to dissolution and dispute
- January 1987: Jesus Jose withdrew and received a P250,000 refund; petitioners closed the restaurant and stored furniture and equipment at respondents’ house without notice.
- March 1, 1987: Respondents signified withdrawal and accepted return of their capital share; October 13, 1987: they complained of asset deterioration and reiterated their refund request.
- November 10, 1987: Respondents filed a complaint for money. Petitioners argued respondents had withdrawn and been paid in kind worth over P400,000, and that no equity refund was due due to business losses. Respondents countered lack of accounting and alleged any loans were personal, not partnership‐chargeable.
- Lower-court and appellate decisions
- RTC (July 21, 1992): Found partnership dissolved; ordered petitioners to pay respondents P250,000 actual damages, P30,000 attorney’s fees, plus costs.
- CA (March 23, 2000): Set aside RTC; held partnership net assets at P1,000,000 less P240,658 debts = P759,342, divided by three → P253,114 per share; ordered petitioners to reimburse respondents P253,114; no pronouncement on costs.
Issues:
- Liability for partnership share
- Are petitioners individually liable to respondents for the latter’s one-third equity?
- Correctness of CA’s computation
- Is the CA’s P253,114 figure legally and factually supported?
- Costs award
- Was the CA correct in making no pronouncement as to costs?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)