Title
Lichauco vs. De Guzman
Case
G.R. No. 10029
Decision Date
Jul 15, 1918
Multiple civil suits over cattle sales; plaintiffs denied partnership, claimed commission agents. Court ruled no partnership, upheld commission basis, ordered payments, and awarded 10% net profits.

Case Summary (G.R. No. 34574)

Consolidation of Cases

Initially, three civil cases were filed: No. 8883 by Lichauco against Guzman, No. 9213 by Del Rio and Olabarrieta against Lichauco, and No. 9217 by Soriano against Lichauco. Due to an agreement among the parties, these were consolidated into a single action for resolution.

Factual Allegations and Counterclaims

The plaintiff alleged that Guzman, operating under the plaintiff's authority, took custody of cattle intended for sale, misappropriating funds amounting to P90,000 intended for Lichauco. Guzman counterclaimed, asserting a joint account partnership agreement dating back to April 14, 1909, where collaboration among the parties aimed to control cattle sales to avoid financial ruin and competition.

Response to Counterclaims

In reply, Lichauco claimed that the relationship was one of agency instead of partnership, whereby he would pay defendants a commission of P1.50 per head sold. The defendants rallied to assert the joint partnership's existence, detailing the profit-sharing proportions agreed upon during their meetings.

Court Proceedings

The trial court found sufficient evidence of a joint account partnership, requiring Lichauco to settle various amounts owed to the defendants. These included P36,800 owed to Soriano and other sums awarded to Guzman, Del Rio, and Olegario. Subsequently, the plaintiffs motioned for a new trial, which was denied, prompting an appeal to the higher court.

Appellate Issues

The court had to address three main issues: the existence and terms of the alleged partnership agreement, the amount of capital provided by the defendants, and whether sales were executed on a commission basis. Lichauco contended the defendants were merely agents, but the testimonies presented established that a partnership had indeed been operational, facilitating an intricate profit-sharing model.

Evidence and Testimonies

The evidence included testimonies asserting the operational partnership contributing to sales success while facing the competitive market. Notably, the defendants' claims of having contributed capital and their involvement in profitable cattle trades were substantiated by various accounts which the court scrutinized extensively.

Legal Findings and Judicial Analysis

The court analyzed the nature of joint account partnerships under the Code of Commerce, examining the crucial requirement for a partnership to be formalized either in writing or through sufficient evidence per legal provisions. The judgment concluded that a partnership was established, legitimizing the claims for profits in accordance with the agreed terms.

Ruling of the Higher Court

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