Title
Claridades vs. Mercader
Case
G.R. No. L-20341
Decision Date
May 14, 1966
Dr. Claridades sued partners for fishpond partnership dissolution; venue contested; Supreme Court ruled personal action, proper in Bulacan, remanded case.

Case Summary (G.R. No. L-20341)

Basis of Appeal

Dr. Simeon S. Claridades filed an appeal from an order of dismissal issued by the Court of First Instance of Bulacan. The dismissal was based on the court’s finding of improper venue for the case. The plaintiff sought not only the dissolution of the partnership and accounting for its assets but also moral and exemplary damages, alongside costs incurred in litigation.

Respondents' Defense

In their response, the defendants, Mercader and Fernandez, acknowledged the existence of the partnership but claimed it had been unproductive. They raised a special defense concerning an impending auction sale of the fishpond due to tax delinquency. Further, they counterclaimed for damages resulting from the initiation of the lawsuit, as well as attorney's fees and costs.

Intervention and Claims

Guillermo Reyes sought to intervene to claim a sum for services rendered as the fishpond foreman. Subsequently, Armando Asuncion intervened as an alleged assignee of Mercader's interest in the partnership and the fishpond. Later, Alfredo Zulueta and his wife Yap Leding also sought to intervene, claiming ownership of half the fishpond based on previous transactions involving Mercader and Asuncion.

Venue Issues and Dismissal

On February 12, 1962, the Zuluetas filed a motion to dismiss, arguing the complaint was moot, stated no cause of action, and that venue was improperly laid. The lower court upheld these claims on March 2, 1962, leading to the dismissal of the case based on improper venue, despite the plaintiff's objections.

Legal Determination of Venue

The pivotal issue on appeal was whether the action should have been initiated in the Court of First Instance of Bulacan or in Marinduque, where the fishpond is located. The lower court concluded that the matter primarily concerned possession of the fishpond, leading to its decision on venue. However, the ruling was found to be erroneous.

Nature of the Action

The Supreme Court clarified that the action initiated by Dr. Claridades was primarily a personal action for the liquidation of the partnership, which could be brought in Bulacan, where the plaintiff resided. The Supreme Court noted that the defendants did not object to the venue during the proceedings, effectively waiving their rights to challenge it.

Implications of Interventions

The Court articulated that even though the plaintiff sought the sale of pa

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