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Week 6 - Extinguishment of Agency

September 16, 2026
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Extinguishment of AgencyArts. 1919-1932

Week 6 Coverage Table

The table below mirrors the syllabus list for September 16, 2026. Entries marked supra re-assign a case already digested; the link points to that original digest.
#Assigned CaseTopic/SubtopicDigest
1CMS Logging, Inc. v. CA, G.R. No. L-41420, July 10, 1992a. Revocation by the principal (Arts. 1920, 1925)
2Central Surety & Insurance Co. v. C.N. Hodges & CA, G.R. No. L-28633, March 30, 1971a. Revocation by the principal (Arts. 1920, 1925) — Express revocation (Arts. 1921-1922)
3CMS Logging, Inc. v. CA, supraa. Revocation by the principal (Arts. 1920, 1925) — Implied revocation (Arts. 1923-1924, 1926)
4International Exchange Bank v. Spouses Briones, G.R. No. 205657, March 29, 2017a. Revocation by the principal (Arts. 1920, 1925) — Implied revocation (Arts. 1923-1924, 1926)
5International Exchange Bank v. Spouses Briones, supraa. Revocation by the principal (Arts. 1920, 1925) — Irrevocable agencies (Art. 1927)
6Lim v. Saban, G.R. No. 163720, December 16, 2004a. Revocation by the principal (Arts. 1920, 1925) — Irrevocable agencies (Art. 1927)
7Mendoza v. Paule, G.R. Nos. 175885 & 176271, February 13, 2009a. Revocation by the principal (Arts. 1920, 1925) — Irrevocable agencies (Art. 1927)
8Valenzuela v. CA, G.R. No. 83122, October 19, 1990a. Revocation by the principal (Arts. 1920, 1925) — Irrevocable agencies (Art. 1927)
9Perez v. Philippine National Bank, G.R. No. L-21813, July 30, 1966c. Death of the principal or the agent (Arts. 1929-1932)
10Rallos v. Felix Go Chan & Sons Realty Corp., suprac. 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.

Study Notes

Revocation is the rule. Agency is founded on trust, so Art. 1920 lets the principal revoke at will, and Art. 1924 revokes it by operation of law the moment the principal starts dealing directly with third persons — the point of CMS Logging, where the principal began selling its logs straight to the Japanese buyers.
Two limits on that rule. The first runs in favor of third persons: under Art. 1922 a revocation the public was never told about does not prejudice someone who dealt with the agent in good faith (Central Surety, where the agent's authority to issue bonds had been withdrawn years earlier but never announced). The second runs in favor of the agent: an agency coupled with an interest cannot be revoked at will (Art. 1927). IEB v. Briones supplies the modern test — where a bilateral contract depends on the agency and the agency was created for the benefit of both parties, it is irrevocable; Lim v. Saban and Valenzuela apply the same idea to a broker's and an insurance agent's stake.
Death. Rallos holds the general line — the death of the principal extinguishes the agency ipso jure, and a sale made by the agent afterwards is void as to the deceased's share, subject to the Art. 1931 exception protecting a third person in good faith who dealt with an agent unaware of the death. Perez v. PNB is the counterpoint: the special power to foreclose written into a mortgage is not an ordinary agency but one coupled with an interest, inseparable from the security, so it survives the mortgagor's death.
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