- Petitioner
- Aniceto G. Saludo, Jr.
- Respondent
- Philippine National Bank
- Citation
- G.R. No. 193138
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Jardeleza, J.
- Decided
- August 20, 2018
Summary
This Supreme Court case definitively established that partnerships for law practice have juridical personality under Philippine Civil Code. SAFA Law Office, formed by Articles of Partnership between Saludo, Agpalo, Fernandez and Aquino, entered lease contract with PNB. When rental disputes arose, lower courts erroneously ruled SAFA Law Office lacked juridical personality. Supreme Court reversed, holding partnerships acquire juridical personality by operation of law under Articles 1768 and 44 of Civil Code, distinguishing Philippine law from American common law. Internal agreements limiting partner liability don't convert partnerships to sole proprietorships. As juridical entity that entered the lease contract, SAFA Law Office is the real party-in-interest that must be joined as plaintiff in litigation concerning that contract. The decision clarifies partnership law principles and real party-in-interest requirements in Philippine civil procedure.