Case Digest Obligations of Partners

8/19/2019 Case Digest Obligations of Partners

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GREGORIO F. ORTEGA v. HON. COURT OF APPEALSG.R. No. 109248. July 3, 199

Facts:

Ortega was then a senior partner in the law firm Bito, Misa, and Lozada withdrew in said firm. Consequently, he filed with!C a petition for dissolution and liquidation of partnership. "owe#er, the latter $!C% ruled in an en &anc decision that withdrawal ofMisa from the firm had dissol#ed the partnership. 'he reason according to said was to the effect that since it is partnership at will,the law firm could &e dissol#ed &y any partner at anytime, such as &y withdrawal therefrom, regardless of good faith or &ad faith,since no partner can &e forced to continue in the partnership against his will.

(ssue: ). *O+ the partnership of Bito, Misa Lozada $now Bito, Lozada, Ortega Castillo% is a partnership at will-. *O+ the withdrawal of Misa dissol#ed the partnership regardless of his good or &ad faith-

"eld:). /es. 'he partnership agreement of the f irm pro#ides that 01t2he partnership shall continue so long as mutually

satisfactory and upon the death or legal incapacity of one of the partners, shall &e continued &y the sur#i#ing partners.0. /es. 3nyone of the partners may, at his sole pleasure, dictate a dissolution of the partnership at will $e.g. &y way of withdrawal of a partner%."e must, howe#er, act in good faith, not that the attendance of &ad faith can pre#ent the dissolution of the partnership &ut that itcan result in a lia&ility for damages

ISA!ELO "ORAN, JR. v. THE HON. COURT OF APPEALS #$% "ARIANO E. PECSON

G.R. No. 99&. O'(o)*+ 31, 1984

Business Organization – Partnership, Agency, Trust – Profit and Loss Sharing – Speculative Damages

FACTS

(n Fe&ruary )45), (sa&elo Moran and Mariano 6ecson entered into a partnership agreement where they agreed to contri&ute

6)78 each for the purpose of printing 478 posters of the delegates to the then )45) Constitutional Commission. Moran shall &e in

charge in managing the printing of the posters. (t was further agreed that 6ecson will recei#e a commission of 6)8 a month starting

from 3pril )45) to 9ecem&er )45)- that the partnership is to &e liquidated on 9ecem&er )7, )45).

6ecson partially fulfilled his o&ligation to the partnership when he issued 6)8 in fa#or of the partnership. "e ga#e the 6)8

to Moran as the managing partner. Moran howe#er did not add anything and, instead, he only used 6;8 out of the 6)8 in printing

, posters. "e only printed , posters &ecause he felt that printing all 478 posters is a losing #enture &ecause of the delay &y

the COM!L!C in announcing the full delegates. 3ll the posters were sold for a total of 6)8.

6ecson sued Moran. 'he trial court ordered Moran to pay 6ecson damages. 'he Court of 3ppeals affirmed the decision of the

trial court &ut modified the same as it ordered Moran to pay 6;5.78 for unrealized profit- 6udgment is correct.

HEL-

+o. 'he award of 6;5.78 for unrealized profit is speculati#e. 'here is no e#idence whatsoe#er that the partnership &etween

the Moran and 6ecson would ha#e &een a profita&le #enture $&ecause &ase on the circumstances then i.e. the delay of the COM!L!Cin proclaiming the candidates, profit is highly unli8ely%. (n fact, it was a failure doomed from the start. 'here is therefore no &asis for

the award of speculati#e damages in fa#or of 6ecson. Further, there is mutual &reach in this case, 6ecson only ga#e 6)8 instead of

6)78 while Moran ga#e nothing at all.

3s for the 6


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any &usiness #enture and the failure of the underta8ing cannot entirely &e &lamed on the managing partner alone, specially if the

latter e?ercised his &est &usiness >udgment, which seems to &e true in this case.

Moran must howe#er return the unused 6@8 of 6ecson=s contri&ution to the partnership plus 6A8 representing 6ecson=s profit

share in the sale of the printed posters. Computation of 6A8 profit share is as follows: $6)8 profit from the sale of the , posters

printed% $6;8 e?pense in printing the 8 posters% $6@8 profit%- 6rofit D 6A8 each.

ILLIA" U/ S. !ARTOLO"E PUON u)((u(*% )y FRANCO PUON

G.R. No. L19819. O'(o)*+ 2&, 1955

CASE -IGEST

F3C':

6uzon entered into a contract with the Eepu&lic of the 6hilippines for the construction of a road and 7 &ridges. "owe#er,6uzon found difficulty in accomplishing &oth pro>ects, so he esta&lished a partnership with y as su&Gcontractor of the pro>ects forfinancial assistance and the profits shall &e di#ided equally &etween them- the resulting partnership is H6 Construction Company0.

'he partners agreed to contri&ute 67, each as capital. "owe#er, 6uzon failed to pay &ut promised to contri&ute hisshare as soon as his application of loan with the 6+B shall &e appro#ed. y ga#e 6uzon ad#ance contri&ution of his share inpartnership for 6uzon top pay his o&ligations with 6+B.

y was entrusted with the management of the pro>ect since 6uzon is &usy with his other pro>ects- whate#er e?pense ymay incur shall &e considered part of his contri&ution. pon appro#al of 6uzon=s loan with the 6+B, he ga#e y 6@, forreim&ursement of y=s contri&ution and 6uzon=s contri&ution to the partnership capital. 'o guarantee the payment of the loan, 6uzonassigned to 6+B all payments to &e recei#ed on account of the contracts with the Bureau of 6u&lic "ighways for the construction- thiswas done without the 8nowledge and consent of y.

Financial demands of the pro>ect increased, thus, y called on 6uzon to place his capital contri&ution- 6uzon failed to do so.y thereafter sent letters of demand to which 6uzon replied that he=s not capa&le of putting additional capital. 6uzon wrote 6Construction Company terminating their su&contract agreement.

y was then not allowed in the office of 6 Construction Company and his authority to deal with B6" was re#o8ed. "ence,he instituted an action against 6uzon see8ing the dissolution of the partnership and payment of damages for the #iolation of thelatter of the terms of their partnership agreement. E'C found that 6uzon failed to contri&ute his share in the capital of thepartnership and caused the failure of partnership to realize e?pected profits. 'he court ordered the dissolution of the partnership and6uzon to pay y a certain sum. Franco 6uzon su&stituted Bartolome 6uzon on the appeal of the case &efore the upreme Court.

(!I:*I+ the amount of money ordered &y the trial court for the failure to contri&ute his share in the capital of the partnership is proper.

EL(+J:

'he award of 6,. as his share in the unrealized profits of the partnership is proper. nder 3rticle of the Ci#ilCode, indemnification for damages shall comprehend not only the #alue of the loss suffered, &ut also that of the profits which theo&ligee failed to o&tain. (n other words lucrum cessans is also a &asis for indemnification. 'here is no dou&t y failed to ma8e profits&ecause of 6uzonKs &reach of contract. 'he partnership showed some profits e#en though the profit and loss statement showed netloss- it may &e due to error in accounting.

"ad the appellant not &een remiss in his o&ligations as partner and as prime contractor of the construction pro>ects inquestion as he was &ound to perform pursuant to the partnership and su&contract agreements, and considering the fact that thetotal contract amount of these two pro>ects is 6,A5,AA7.5@, it is reasona&le to e?pect that the partnership would ha#e earnedmuch more than the 6AA;,77.@) *e ha#e hereina&o#e indicated. 'he award, therefore, made &y the trial court of the amount of6,., as compensatory damages, is not speculati#e, &ut &ased on reasona&le estimate.

3s cited in Moran #s. C3:

'he rule is, when a partner who has underta8en to contri&ute a sum of money fails to do so, he &ecomes a de&tor of thepartnership for whate#er he may ha#e promised to contri&ute $3rt. )5


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Furthermore, in the y case, only 6uzon failed to gi#e his full contri&ution while y contri&uted much more than what wase?pected of him.

EANGELISTA 6 CO., *( #l. v. ESTRELLA A!A- SANTOS

G.R. No. L31&84. Ju$* 28, 1953

F3C':

On Octo&er 4, )47; a coGpartnership was formed under the name of !#angelista Co. On une 5, )477 the 3rticles of CoGpartnership were amended so as to include herein respondent, !strella 3&ad antos, as industrial partner, with herein petitioners

9omingo C. !#angelista, r., Leonarda 3tienza 3&ad antos and Conchita 6. +a#arro, the original capitalist partners, remaining in that

capacity, with a contri&ution of 6)5,7 each

On 9ecem&er )5, )4@A herein respondent filed suit against the three other partners, alleging that the partnership, whichwas also made a partyGdefendant, had &een paying di#idends to the partners e?cept to her- and that notwithstanding her demandsthe defendants had refused and continued to refuse to let her e?amine the partnership &oo8s or to gi#e her information regardingthe partnership affairs or to pay her any share in the di#idends declared &y the partnership.

'he defendants, in their answer, denied e#er ha#ing declared di#idends or distri&uted profits of the partnership- deniedli8ewise that the plaintiff e#er demanded that she &e allowed to e?amine the partnership &oo8s- and &y way of affirmati#e defensealleged that the amended 3rticles of CoGpartnership did not e?press the true agreement of the parties, which was that the plaintiffwas not an industrial partner- that she did not in fact contri&ute industry to the partnership.

(!: *hether 3&ad antos is entitled to see the partnership &oo8s &ecause she is an industrial partner in the partnership

"!L9:/es, 3&ad antos is entitled to see the partnership &oo8s.'he upreme Court ruled that according to 3E'. )44. 3ny partner shall ha#e the right to a formal account as to partnership

affairs:

$)%(f he is wrongfully e?cluded from the partnership &usiness or possession of its property &y his coGpartners-

$%(f the right e?ists under the terms of any agreement-$A%3s pro#ided &y article )ust and reasona&le.

(n the case at hand, the company is estopped from denying 3&ad antos as an industrial partner &ecause it has &een <years and the company ne#er corrected their agreement in order to show their true intentions. 'he company ne#er &othered tocorrect those up until 3&ad antos filed a complaint.

"ARS"AN -R/S-ALE LAN-, INC., S. PHILIPPINE GEOANAL/TICS, INC. AN- GOTESCO PROPERTIES, INC.G.R. No. 183354 Ju$* 29, 2010

Facts:Marsman 9rysdale, (nc. $Marsman% and Jotesco 6roperties, (nc. $Jotesco% entered into a >oint #enture agreement for the

construction and de#elopment of an office &uilding on a land owned &y Marsman. 'hey agreed on a 7G7 ratio on the proceeds ofthe pro>ect, &ut did not agree on how losses would &e di#ided. 'he >oint #enture engaged the ser#ices of 6hilippine Jeoanalytics, (nc$6J(% to pro#ide su&surface soil e?ploration, seismic study and geotechnical engineering. 6J( completed its seismic study &ut failedto complete its su&surface soil e?ploration &ecause the area where drilling was to &e made had not &een cleared. 'he &uilding pro>ectwas su&sequently shel#ed due to unfa#ora&le economic conditions. 6J( &illed the >oint #enture for wor8 done, &ut was not paiddespite its repeated demands. 6J(, thus, filed a collection case against Marsman and Jotesco. Marsman passed the o&ligation toJotesco &ecause under the >oint #enture agreement, Jotesco was solely lia&le for the monetary e?penses of the pro>ect, and

Marsman=s participation was limited to the land. Jotesco, on the other hand, asserted that 6J( had to cause of action against it as6J( had yet to complete the ser#ices in itscontract, and it was Marsman=s failure to clear the property of de&ris which pre#ented 6J(from completing its wor8.

(ssue:*ho &etween Marsman and Jotesco was lia&le to pay 6J( its unpaid claimsN

"eld:Marsman and Jotesco are >ointly lia&le to 6J(.

6J( was ne#er a party to the >oint #enture agreement. *hile the >oint #enture agreement clearly spelled out the capitalcontri&utions of Marsman $land% and Jotesco $cash% and the funding mechanism, it cannot &e used to defeat the lawful claim of6J( against the two >oint #enturersGpartners. 6J(=s contract clearly listed the >oint #enturers Marsman and Jotesco as the&eneficial owner of the pro>ect, and all &illing in#oices indicated the consortium as the client.

*hen there are two or more de&tors, the o&ligation is presumed to &e >oint unless the law or the o&ligation e?pressly statesthat the lia&ility is solidary, or unless the nature of the o&ligation requires solidary lia&ility $3rticles )5 and )oint &etween Marsman and Jotesco.

3 >oint #enture &eing a form of partnership, it is to &e go#erned &y the laws on partnership. nder the laws onpartnership, particularly 3rticle )545 of the Ci#il Code, the losses and profits shall &e distri&uted in accordance with the agreement- if


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only the share of each partner in the profits has &een agreed upon, the share of each in the losses shall &e in the sameproportion.

(n the >oint #enture agreement, Marsman and Jotesco agreed on a 7G7 ratio on the proceeds of the pro>ect, &ut did not

pro#ide for the splitting of losses. 3pplying 3rticle )545, the same ratio applies in splitting the o&ligationGloss of the >oint #enture to6J(.

FE-ERICO JARANTILLA S. ANTONIETA JARANTILLA

G.R. No. 1448&, -*'*7)*+ 01 2010

F3C':

'he present case stems from the complaint filed &y 3ntonieta arantilla against Buena#entura Eemotigue, CynthiaEemotigue, Federico arantilla, r., 9oroteo arantilla and 'omas arantilla, for the accounting of the assets and income of the coGownership, for its partition and the deli#ery of her share corresponding to eight percent $ect realproperties% in the name of the defendants since the only way the defendants could ha#e purchased these properties were throughthe partnership as they had no other source of income. 'he respondents did not deny the e?istence and #alidity ofthe3c8nowledgement of 6articipating Capital and in fact used this as e#idence to support their claim that 3ntonieta=s ect of the 3c8nowledgement of 6articipating Capital funded the su&>ect real properties.

"!L9:nder 3rticle )5@5 of the Ci#il Code, there are two essential elements in a contract of partnership:$a% an agreement to

contri&ute money, property or industry to a common fund- and $&% intent to di#ide the profits among the contracting parties. 'hefirst element is undou&tedly present in the case at &ar, for, admittedly, all the parties in this case ha#e agreed to, and did, contri&utemoney and property to a common fund. "ence, the issue narrows down to their intent in acting as they did. (t is not denied that allthe parties in this case ha#e agreed to contri&ute capital to a common fund to &e a&le to later on share its profits. 'hey ha#eadmitted this fact, agreed to its #eracity, and e#en su&mitted one common documentary e#idence to pro#e such partnership G the3c8nowledgement of 6articipating Capital. 'he petitioner himself claims his share to &e @, as stated in the 3c8nowledgement of6articipating Capital. "owe#er, petitioner fails to realize that this document specifically enumerated the &usinesses co#ered &y thepartnership: Manila 3thletic upply, Eemotigue 'rading in (loilo City and Eemotigue 'rading in Cota&ato City. ince there was a clearagreement that the capital the partners contri&uted went to the three &usinesses, then there is no reason to de#iate from suchagreement and go &eyond the stipulations in the document. 'here is no e#idence that the su&>ect real properties were assets of the

partnership referred to in the 3c8nowledgement of 6articipating Capital. 6etition denied.

CHOITHRA" JETH"AL RA"NANI #$%o+ NIR"LA . RA"NANI AN- "OTI G. RA"NANI v. COURT OF APPEALS

G.R. No. 8494. "#y 5, 1991

FACTS:

(shwar ethmal Eamnani and his wife onya had their main &usiness &ased in +ew /or8. (shwar recei#ed P)7,.from his fatherGinGlaw in witzerland. (n )4@7, (shwar ethmal Eamnani sent the amount of P)7,. to Choithram in two&an8 drafts of P@7,. and P


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did not e?hi&it any commercial document as regard to the alleged remittances. (t &elie#ed the claim of Choitram that he and (shwarentered into a temporary arrangement in order to ena&le Choithram, then a British citizen, to purchase the properties in the name of (shwar who was an 3merican citizen and who was then qualified to purchase property in the 6hilippines under the then 6arity3mendment.

pon appeal, the C3 re#ersed the decision and ga#e credence to (shwar. (t upheld the #alidity of (shwar=s testimony andga#e cognizance to a letter written &y Choihtram imploring (shwar to renew the power of attorney after it was re#o8ed. (t statestherein that Choithram reassures his &rother that he is not after his money and that the re#ocation is hurting the reputation of(shwar. Choithram also made no mention of his claimed temporary arrangement in the letter. 'he C3 ruled that Choithram is also

estopped in pais or &y deed from claiming an interest o#er the properties. Because of Choitram=s admissions from $)% power ofattorney, $% the 3greements, and $A% the Contract of Lease. (t furthermore "!L9 that ChoithramKs Ktemporary arrangement, &y

which he claimed purchasing the two $% parcels in question in )4@@ and placing them in the name of (shwar who is an 3mericancitizen circum#ents the disqualification pro#ision of aliens acquiring real properties in the 6hilippines. pholding the supposedtemporary arrangement with (shwar would &e sanctioning the perpetration of an illegal act and culpa&le #iolation of theConstitution.

9uring the pendency of the case, Choithram made se#eral attempts to dispose of his properties &y way of donation and alsomortgaged the properties under litigation for A million 9 to a shell partnership with a mere capital of ) 9.

'he upreme Court affirms the findings of the Court of 3ppeals.

ISSUES:

). *hether or not there was a partnership &etween the &rothers (shwar and Choithram. *hether or not Ortigas Ltd. is lia&le.

HEL-:

). /es, there is a partnership &etween the &rothers e#en without a written agreement, the scenario is clear. pouses (shwar

supplied the capital of P)7,. for the &usiness. 'hey entrusted the money to Choithram to in#est in a profita&le&usiness #enture in the 6hilippines. For this purpose they appointed Choithram as their attorneyGinGfact.

Choithram in turn decided to in#est in the real estate &usiness. "e &ought the two $% parcels of land in question fromOrtigas as attorneyGinGfact of (shwarG (nstead of paying for the lots in cash, he paid in installments and used the &alance of thecapital entrusted to him, plus a loan, to &uild two &uildings. 3lthough the &uildings were &urned later, Choithram was a&le to &uildtwo other &uildings on the property. "e rented them out and collected the rentals. 'hrough the industry and genius of Choithram,(shwarKs property was de#eloped and impro#ed into what it is nowQa #alua&le asset worth millions of pesos.

*e ha#e a situation where two &rothers engaged in a &usiness #enture. One furnished the capital, the other contri&uted hisindustry and talent. ustice and equity dictate that the two share equally the fruit of their >oint in#estment and efforts. 6erhaps thisolomonic solution may pa#e the way towards their reconciliation. Both would stand to gain. +o one would end up the loser. 3fter all,

&lood is thic8er than water.

"owe#er, &ecause of the de#ious machinations and schemes that Choithram employed he should pay moral and e?emplarydamages as well as attorneyKs fees to spouses (shwar.

. /es, &ecause Ortigas had se#eral notices of the re#ocation. 9espite said notices, Ortigas ne#ertheless acceded to therepresentation of Choithram, as alleged attorneyGinGfact of (shwar, to assign the rights of petitioner (shwar to +irmla. *hilethe primary &lame should &e laid at the doorstep of Choithram, Ortigas is not entirely without fault. (t should ha#e requiredChoithram to secure another power of attorney from (shwar. For rec8lessly &elie#ing the pretension of Choithram that hispower of attorney was still good, it must, therefore, share in the latterKs lia&ility to (shwar.

E. ". !ACHRACH v. LA PROTECTORA ET AL.

G.R. No. L11&24. J#$u#+y 21, 1918

Facts:+icolas egundo, 3ntonio 3diarte, (gnacio Flores and Modesto errano $defendants% formed a ci#il partnership called HLa

6rotectora0 for the purpose of engaging in the &usiness of transporting passengers and freight at Laoag, (locos +orte. Marcelo Bar&a,acting as manager, negotiated for the purchase of automo&ile truc8s from !. M. Bachrach for 6)@,7. Bar&a paid 6A, in cashand for the &alance e?ecuted promissory notes.

One of these promissory notes was signed in the following manner: H6.6 La 6rotectora, By Marcelo Bar&a Marcelo Bar&a0 'he other notes were signed in the same way &ut the word H&y0 was omitted. (t was oious that in signing the notes, Bar&a

intended to &ind &oth the partnership and himself.

'he defendants e?ecuted a document in which they declared that they were mem&ers of La 6rotectora and that they hadgranted to its president full authority to contract for the purchase of the automo&iles. 'he document was deli#ered &y Bar&a toBachrach at the time the #ehicles were purchased.

Bar&a incurred a de&t amounting to 6,@)5.75 and Bachrach foreclosed a chattel mortgage on the truc8s &ut there was still&alance. 'o reco#er the &alance, action was instituted against the defendants. udgment was rendered against the defendants.


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(ssue:a.*hether or not the defendants are lia&le for the firm de&ts.&.*hether or not Bar&a had authority to incur e?penses for the partnership $rele#ant issue%

"eld:a./es. 6romissory notes constitute the o&ligation e?clusi#ely of La 6rotectora and Bar&a. 'hey do not constitute an o&ligation directly&inding the defendants. 'heir lia&ility is &ased on the principles of partnership lia&ility. 3 mem&er is not lia&le in solidum with hisfellows for the entire inde&tedness &ut is lia&le with them or his aliquot part.

C o&iter: the document was intended merely as an authority to ena&le Bar&a to &ind the partnership and that the parties to the

instrument did not intend to confer upon Bar&a an authority to &ind them personally.

&. /es. nder 3rt )oined from ta8ing any further action insaid ci#il case ga#e and e?cept as herein indicated. Costs against pri#ate respondent.

-AN FUE LEUNG v. HON. INTER"E-IATE APPELLATE COURT #$% LEUNG /IU


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G.R. No. 5092&. J#$u#+y 31, 1989

F3C':

'he petitioner as8s for the re#ersal of the decision of the 3ppellate Court in which affirmed the decision of the lower courtdeclaring pri#ate respondent Leung /iu a partner of petitioner 9an Fue Leung in the &usiness of un *ah 6anciteria and ordering thepetitioner to pay to the pri#ate respondent his share in the annual profits of the said restaurant.

'his case originated from a complaint filed &y respondent Leung /iu with the lower court to reco#er the sum equi#alent totwentyGtwo percent $% of the annual profits deri#ed from the operation of un *ah 6anciteria since Octo&er, )477 from petitioner

9an Fue Leung.

'he un *ah 6anciteria was registered as a single proprietorship and its licenses and permits were issued to and in fa#or ofpetitioner 9an Fue Leung as the sole proprietor. Eespondent Leung /iu adduced e#idence during the trial of the case to show thatun *ah 6anciteria was actually a partnership and that he was one of the partners ha#ing contri&uted 6;,. to its initialesta&lishment.

Lower court ruled in fa#or of the pri#ate respondent. 6etitioner appealed the trial courtKs amended decision. "owe#er, thequestioned decision was further modified and affirmed &y the appellate court. Both the trial court and the appellate court declaredthat the pri#ate petitioner is a partner and is entitled to a share of the annual profits of the restaurant. "ence, an appeal to the C.'he petitioner argues that pri#ate respondent e?tended Kfinancial assistanceKto herein petitioner at the time of the esta&lishment ofthe un *ah 6anciteria, in return of which pri#ate respondent allegedly will recei#e a share in the profits of the restaurant. (t was,therefore, error for the 3ppellate Court to interpretor construe Kfinancial assistanceK to mean the contri&ution of capital &y a partnerto a partnership.

(!:*O+ the pri#ate respondent is a partner of the petitioner in the esta&lishment of un *ah 6anciteria.

"!L9:

(n essence, the pri#ate respondent alleged that when un *ah 6anciteria was esta&lished, he ga#e 6;,. to thepetitioner with the understanding that he would &e entitled to twentyGtwo percent $% of the annual profit deri#ed from theoperation of the said panciteria. 'hese allegations, which were pro#ed, ma8e the pri#ate respondent and the petitioner partners inthe esta&lishment of un *ah 6anciteria &ecause 3rticle )5@5 of the Ci#il Code pro#ides thatBy the contract of partnership two ormore persons &ind themsel#es to contri&ute money, property or industry to a common fund, with the intention of di#iding the profitsamong themsel#es.

'herefore, the lower courts did not err in construing the complaint as one wherein the pri#ate respondent asserted his rightsas partner of the petitioner in the esta&lishment of the un *ah 6anciteria, notwithstanding the use of the term financial assistancetherein.

C affirmed appellate court=s decision and ordered the dissolution of the partnership.

E"ILIO E"NACE v. COURT OF APPEALS

G.R. No. 12&334. Nov*7)*+ 23, 2001

CASE -IGEST

FACTS !milio !mnace, acinto 9i#inagracia and Sicente 'a&anao formed a partnership engaged in the fishing industry. (n )4


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NOTE nder 3rticle )ust one of the e?ceptions. Jeneral Eule: 3ccounting only when there is dissolution. !?ception: 3rticle )

Case Digest Obligations of Partners

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