Teodoro de Los Reyes v. Vicente Lukban

Summary

This 1916 Supreme Court case established important precedents for partnership liability in Philippine commercial law. Creditor Teodoro de los Reyes sued individual partners Vicente Lukban and Espiridion Borja to collect the unpaid balance of a commercial debt originally owed by their dissolved partnership. The Court affirmed that when a partnership has no assets, creditors may pursue individual partners for the full debt under Article 127 of the Code of Commerce, which makes partners personally and severally liable. The Court distinguished this action from a previous case against the partnership itself, ruling that res judicata did not apply since different parties and legal capacities were involved. The decision reinforced the principle that partnership dissolution does not extinguish partners' personal liability for firm debts, providing important protection for commercial creditors in the early American colonial period of Philippine jurisprudence.