Contract of agency, express and implied trusts, and the formation, operation, and dissolution of partnerships
On item 9. Eurotech is assigned here for Arts. 1876-1877, but the decision never cites either article by number — its discussion of the "general agent or manager" rests on 3 Am Jur 2d §91. The codal link is a pedagogical inference, not the Court's own.
| Case | What it is for | Categorical holding |
|---|---|---|
| Eurotech v. Cuizon | Principle, purpose, basis; agent's non-liability to third persons; breadth of a managing agency | Agent acted within authority; not personally liable under Art. 1897; not a real party in interest |
| Doles v. Angeles | Purpose of agency operating as ratio; substance over nomenclature | Both parties were agents; not privy to the principals' loan; sale void for want of cause |
| Angeles v. PNR | Third party's liability runs to the principal; agent cannot sue | Lizette was agent, not assignee; no standing to sue PNR |
| Rallos v. Felix Go Chan | Source of the four-element formulation; representative/derivative character | Agency extinguished by death; Art. 1931 inapplicable, the agent having known of the death |
| Bordador v. Luz | Consent of the principal is indispensable; duty of inquiry | No express or implied agency proven; alleged principal absolved |
| Litonjua v. Eternit | Mutual consent; corporate consent must come from the board | No agency with EC; board resolution a condition sine qua non |
| Orient Air v. CA | Essential characteristics; consensual and representative | No judicial reinstatement of a terminated agent |
| Philex Mining v. CIR | Agency v. partnership/joint venture; agency v. loan; Art. 1927 corrected | "Power of Attorney" was a partnership; advances were capital, not bad debts |
| Sps. Viloria v. Continental | Agency v. sale — who holds title and who is bound | Holiday Travel is CAI's agent, not a buyer-reseller; but no vicarious tort liability |
| # | Assigned Case | Topic/Subtopic | Class. | Digest |
|---|---|---|---|---|
| 1 | Equitable PCI-Bank v. Ku, G.R. No. 142950, March 26, 2001 | a. How agency is constituted (Arts. 1869-1872; cf: Art. 1317) | INCIDENTAL | |
| 2 | Gonzales-Saldana v. Spouses Niamatali, G.R. No. 226587, November 21, 2018 | a. How agency is constituted (Arts. 1869-1872; cf: Art. 1317) | DIRECT | |
| 3 | Silva v. Lo, G.R. No. 206667, June 23, 2021 | b. Perfection of the contract of agency as it affects third persons (Art. 1873; cf: Art. 1911) | ANALOGOUS | |
| 4 | Litonjua, Jr. v. Eternit Corp., G.R. No. 144805, June 8, 2006, supra | b. Perfection of the contract of agency as it affects third persons (Art. 1873; cf: Art. 1911) | REJECTED | |
| 5 | Angeles v. Philippine National Railways, supra | c. Formal requirements on grant of powers to agent (Arts. 1874; 1878-1880) — Form of agency (Art. 1869, par. 2) | DIRECT | |
| 6 | AF Realty & Development, Inc. v. Dieselman Freight Services Co., G.R. No. 111448, January 16, 2002 | c. Formal requirements on grant of powers to agent (Arts. 1874; 1878-1880) — Sale of land through an agent (Art. 1874) | DIRECT | |
| 7 | Spouses Bautista v. Spouses Jalandoni & Manila Credit Corp.; Manila Credit Corp. v. Spouses Jalandoni & Spouses Bautista, G.R. Nos. 171464 & 199341, November 27, 2013 | c. Formal requirements on grant of powers to agent (Arts. 1874; 1878-1880) — Sale of land through an agent (Art. 1874) | DIRECT | |
| 8 | Mactan-Cebu International Airport Authority v. Unchuan, G.R. No. 182537, June 1, 2016 | c. Formal requirements on grant of powers to agent (Arts. 1874; 1878-1880) — Sale of land through an agent (Art. 1874) | DIRECT | |
| 9 | Alfiler v. Spouses Cayabyab, G.R. No. 217111, March 13, 2023 | c. Formal requirements on grant of powers to agent (Arts. 1874; 1878-1880) — Sale of land through an agent (Art. 1874) | DIRECT | |
| 10 | Dominion Insurance Corp. v. CA, G.R. No. 129919, February 6, 2002 | c. Formal requirements on grant of powers to agent (Arts. 1874; 1878-1880) — When special power of attorney required (Art. 1878) | DIRECT | |
| 11 | San Miguel Corporation v. Trinidad, G.R. No. 237506, July 28, 2020 | c. Formal requirements on grant of powers to agent (Arts. 1874; 1878-1880) — Power to sell and power to mortgage (Art. 1879) | ANALOGOUS | |
| 12 | The Commoner Lending Corp. v. Spouses Villanueva, G.R. No. 235260, August 27, 2020 | c. Formal requirements on grant of powers to agent (Arts. 1874; 1878-1880) — Power to sell and power to mortgage (Art. 1879) | ANALOGOUS |
| Case | What it is for | Categorical holding |
|---|---|---|
| Equitable PCI Bank v. Ku | Implied constitution; the two codal texts of subtopic (a) | Facts "inadequate" to show no agency; petition granted anyway on suspension of the rules |
| Gonzales-Saldana v. Niamatali | The clean Week 2(a) authority; agency inferred "from all the dealings" | Implied agency existed "for the purpose of purchasing the Las Piñas property"; agent acted beyond it |
| Silva v. Lo | Revocation not communicated to the agent | Principal "continued to clothe" agent with apparent authority; and impliedly ratified under Art. 1317 par. 2 |
| Litonjua v. Eternit (Wk 2) | Three-element test for agency by estoppel | No estoppel — "[s]uch proof is lacking"; agents spoke for ESAC, not EC |
| Angeles v. PNR (Wk 2) | General rule of form; office of a power of attorney | Letter sufficient as a power of attorney; but strictly construed — "to withdraw" ≠ to sue |
| AF Realty v. Dieselman | Art. 1874 nullity; no ratification | Sale void; ₱300,000 "earnest money" did not cure it; nemo dat down the broker chain |
| Sps. Bautista v. Sps. Jalandoni | Art. 1874 + Art. 1878(5); buyer's peril | Sale void; buyers not in good faith for failing to demand the SPA |
| MCIAA v. Unchuan | Dizon content standard; durability of the nullity | Void as to non-signing co-owners; valid as to Atanacio's own pro indiviso share (Art. 493) |
| Alfiler v. Sps. Cayabyab | The SPA must be offered in evidence | Deed void ab initio; ejectment complaint dismissed for want of any right of possession |
| Dominion Insurance v. CA | General v. special agency; acts of administration | A document titled "Special Power of Attorney" was a general agency; settling claims needed a special power |
| SMC v. Trinidad | Scope of a special power over an immovable | "To offer as collateral" is authority to mortgage; owners bound also by apparent authority |
| Commoner Lending v. Villanueva | Special power to sell in extrajudicial foreclosure | Paragraph 3 "sufficiently incorporated" the special power to sell; foreclosure valid |
| # | Assigned Case | Topic/Subtopic | Digest |
|---|---|---|---|
| 1 | San Miguel Corporation v. Trinidad, G.R. No. 237506, July 28, 2020, supra | e. Obligation to act in accordance with the principal's instructions and to be diligent (Art. 1887, cf: Art. 1902, Art. 1888) | |
| 2 | Spouses Villaluz v. Land Bank of the Philippines, G.R. No. 192602, January 18, 2017 | h. Power of agent to appoint a substitute (Arts. 1892-1893) | |
| 3 | Serona v. Court of Appeals, G.R. No. 130423, November 18, 2002 | h. Power of agent to appoint a substitute (Arts. 1892-1893) | |
| 4 | National Power Corp. v. National Merchandising Corp., G.R. Nos. L-33819 & L-33897, October 23, 1982 | j. When agent personally liable to third persons (Art. 1897) | |
| 5 | Development Bank of the Phils. v. Court of Appeals, G.R. No. 109937, March 21, 1994 | j. When agent personally liable to third persons (Art. 1897) | |
| 6 | Cervantes v. CA, G.R. No. 125138, March 2, 1999 | m. Consequences if agent contracts in the name of the principal and if he contracts in his own name (Arts. 1898, 1893) | |
| 7 | Rural Bank of Bombon (Camarines Sur), Inc. v. CA, G.R. No. 95703, August 3, 1992 | m. Consequences if agent contracts in the name of the principal and if he contracts in his own name (Arts. 1898, 1893) | |
| 8 | Green Valley Poultry & Allied Products, Inc. v. IAC, G.R. No. L-49395, December 26, 1984 | o. Specific obligation rules for commission agents (Arts. 1903-1909) — Ordinary agent v. Commission agent |
Note on the syllabus outline. Item (m) is captioned "Consequences if agent contracts in the name of the principal and if he contracts in his own name (Arts. 1898, 1893)." The article governing an agent who contracts in his own name is Art. 1883, not Art. 1893 (which concerns the appointment of a substitute and belongs to item (h)). The topic labels above reproduce the syllabus as written; the digests discuss Arts. 1898 and 1883, which are the provisions the caption actually describes.
| # | Assigned Case | Topic/Subtopic | Digest |
|---|---|---|---|
| 1 | Spouses Salvador v. Spouses Rabaja, G.R. No. 199990, February 4, 2015 | a. Principal's liability for acts of agent within the scope of authority (Art. 1910) | |
| 2 | Pleasantville Development Corp. v. CA, G.R. No. 79688, February 1, 1996 | a. Principal's liability for acts of agent within the scope of authority (Art. 1910) | |
| 3 | Manila Remnant Co., Inc. v. CA, G.R. No. 82978, November 22, 1990 | b. Principal's liability for acts of agent in excess of authority (Arts. 1910 & 1911) — Solidary liability of principal and agent (Arts. 1911) | |
| 4 | De Castro v. CA, G.R. No. 115838, July 18, 2002 | c. Liability of two or more principals to commonly appointed agent (Art. 1915) |
| # | Assigned Case | Topic/Subtopic | Digest |
|---|---|---|---|
| 1 | CMS Logging, Inc. v. CA, G.R. No. L-41420, July 10, 1992 | a. Revocation by the principal (Arts. 1920, 1925) | |
| 2 | Central Surety & Insurance Co. v. C.N. Hodges & CA, G.R. No. L-28633, March 30, 1971 | a. Revocation by the principal (Arts. 1920, 1925) — Express revocation (Arts. 1921-1922) | |
| 3 | CMS Logging, Inc. v. CA, supra | a. Revocation by the principal (Arts. 1920, 1925) — Implied revocation (Arts. 1923-1924, 1926) | |
| 4 | International Exchange Bank v. Spouses Briones, G.R. No. 205657, March 29, 2017 | a. Revocation by the principal (Arts. 1920, 1925) — Implied revocation (Arts. 1923-1924, 1926) | |
| 5 | International Exchange Bank v. Spouses Briones, supra | a. Revocation by the principal (Arts. 1920, 1925) — Irrevocable agencies (Art. 1927) | |
| 6 | Lim v. Saban, G.R. No. 163720, December 16, 2004 | a. Revocation by the principal (Arts. 1920, 1925) — Irrevocable agencies (Art. 1927) | |
| 7 | Mendoza v. Paule, G.R. Nos. 175885 & 176271, February 13, 2009 | a. Revocation by the principal (Arts. 1920, 1925) — Irrevocable agencies (Art. 1927) | |
| 8 | Valenzuela v. CA, G.R. No. 83122, October 19, 1990 | a. Revocation by the principal (Arts. 1920, 1925) — Irrevocable agencies (Art. 1927) | |
| 9 | Perez v. Philippine National Bank, G.R. No. L-21813, July 30, 1966 | c. Death of the principal or the agent (Arts. 1929-1932) | |
| 10 | Rallos v. Felix Go Chan & Sons Realty Corp., supra | c. Death of the principal or the agent (Arts. 1929-1932) |
Note on the syllabus citation. The list gives Perez v. PNB as G.R. No. L-21812. The decision is reported at G.R. No. L-21813, July 30, 1966; the digest uses the reported citation.
| # | Assigned Case | Topic/Subtopic | Digest |
|---|---|---|---|
| 1 | Goyanko, Jr. v. United Coconut Planters Bank, G.R. No. 179096, February 6, 2013 | 1. Express Trusts (Arts. 1443 - 1446) — Elements | |
| 2 | Cañezo v. Rojas, G.R. No. 148788, November 23, 2007 | 1. Express Trusts (Arts. 1443 - 1446) — How proven (Art. 1443) | |
| 3 | Cañezo v. Rojas, supra | 1. Express Trusts (Arts. 1443 - 1446) — Creation of an express trust (Art. 1444) | |
| 4 | Torbela v. Spouses Rosario, G.R. Nos. 140528 & 140553, December 7, 2011 | 2. Implied Trusts (Art. 1447 - 1457) — a. Resulting Trusts (Art. 1448-1455) — Legal title to land inherited by heir but placed in the name of another (Art. 1451) | |
| 5 | Sumaoang v. Judge, RTC, Br. XXXI, Guimba, Nueva Ecija, G.R. No. 78173, October 26, 1992 | 2. Implied Trusts (Art. 1447 - 1457) — b. Constructive Trusts — Acquisition of property through mistake or fraud (Art. 1456) | |
| 6 | Spouses Aboitiz v. Spouses Po, citing Hortizuela v. Tagufa, G.R. Nos. 208450 & 208497, June 5, 2017 | 2. Implied Trusts (Art. 1447 - 1457) — b. Constructive Trusts — Reconveyance | |
| 7 | Gatmaytan and Valdellon v. Misibis Land, Inc., G.R. No. 222166, June 10, 2020 | 2. Implied Trusts (Art. 1447 - 1457) — b. Constructive Trusts — Prescriptive period to file reconveyance | |
| 8 | Heirs of Tulauan v. Mateo, G.R. No. 248974, September 7, 2022 | 2. Implied Trusts (Art. 1447 - 1457) — b. Constructive Trusts — Prescriptive period to file reconveyance | |
| 9 | GSIS v. Santiago, citing Adille v. CA, G.R. No. 155206, October 28, 2003 | 2. Implied Trusts (Art. 1447 - 1457) — b. Constructive Trusts — Prescriptive period to file reconveyance |
Notes on the syllabus. (1) Torbela v. Rosario is given in the list as G.R. No. 140428; the decision is reported at G.R. Nos. 140528 & 140553, December 7, 2011. (2) The Misibis Land case is captioned Gatmaytan and Valdellon v. Misibis Land, Inc. — Valdellon is the second of two petitioners. The digests use the reported citations. (3) Torbela is assigned under resulting trusts (Art. 1451), but the Court characterised the arrangement as an express trust on the strength of Dr. Rosario's written acknowledgment — treat it as analogous to Art. 1451 rather than a direct application, and see the Syllabus Note in that digest.