Petitioner
Michael C. Guy
Respondent
Atty. Glenn C. Gacott
Citation
G.R. No. 206147
Court
Supreme Court
Division
Second Division
Ponente
Mendoza, J.
Decided
January 13, 2016

Summary

The Supreme Court reversed the lower courts' decisions allowing attachment of Michael Guy's personal property to satisfy a partnership debt. Guy was the General Manager of Quantech Systems Corporation (QSC), a partnership that lost a damages case filed by Atty. Gacott over defective transreceivers. When Guy's vehicle was attached during execution, he filed a motion to lift attachment arguing he was not a judgment debtor. The SC ruled that: (1) a partner must be separately impleaded before being bound by judgment against the partnership; (2) partners' liability is subsidiary (after partnership assets are exhausted) and generally joint, not solidary; (3) solidary liability only applies when caused by a partner's wrongful act, which was not proven here. The case establishes important precedent on due process requirements for holding partners liable for partnership debts and the distinction between joint and solidary liability in partnership law.

Statutes applied

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By Intellegal Editorial Board · January 13, 2016

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