Sobre el incumplimento contractual entre un artista y su compañía discográfica

Los hermanos Adrián Marcelo y Orlando Javier Torres Ruiz Díaz (ex integrantes del grupo “Red“), asumieron por contrato la obligación de grabar durante un trienio y en exclusividad, para Leader Music (discográfica) diversos fonogramas.

Al vencimiento de aquél, Leader Music hizo uso de la facultad contractual de prorrogar el acuerdo por un nuevo período de tiempo. Asimismo, a fin de evitar el incumplimiento de la cláusula de exclusividad resultante del contrato, remitió comunicaciones a B.G.M. (otra discográfica)y a “Editorial Atlántida”, entre otros, advirtiéndoles que los citados artistas se encontraban impedidos de grabar con empresas competidoras, por encontrarse contratados (en condiciones de exclusividad), por “Leader Music”.

No obstante ello y en plena vigencia del contrato señalado, “Editorial Atlántida“, obsequió con la compra de la revista “Juntos” un CD con la imagen de Orlando Javier Torres Ruiz Díaz y 4 temas interpretados por el “Grupo Red”, editado y producido por “Wemi“.

Leader Music promovió demanda contra: i) Editorial Atlántida S.A., ii) Wemi S.A. y, iii) Adrián Marcelo Torres Ruiz Díaz.

grupo red

La Sala B de la Cámara de Apelaciones en lo Comercial: 1) mantuvo la condena de primera instancia contra el último de los nombrados (Adrían Marcelo Torres Ruiz Díaz), en base al incumplimiento del contrato vigente; 2) extendió la condena a Wemi, al tener por acreditado que dicha empresa constituyó una mera pantalla para violar por su intermedio la cláusula de exclusividad de artistas (los elementos acompañados a autos, permitieron demostrar la íntima vinculación habida entre B.G.M. y Wemi). 3) Finalmente el tribunal de alzada realizó una estricta aplicación de la máxima “res inter alios acta” o principio de la EFICACIA RELATIVA DE LOS CONTRATOS, conforme al cual los contratos sólo surten efectos entre las partes y sus sucesores, mas no perjudican ni benefician a terceros. Con fundamento en tal regla, la Sala rechazó la pretensión indemnizatoria contra “Editorial Atlántida”, en su calidad de TERCERO respecto del contrato que tuviera por partes a Leader Music y los hermanos Torres.

Para ver el fallo completo: Leader Music S.A.C.I.M. c. Editorial Atlántida S.A. y otros s/ ordinario • 23/05/2013 (Publicado en: La Ley Online. Cita online: AR/JUR/26603/2013)

 

Rosario, 28 de octubre de 2013

 

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