Constante Amor de Castro v. Court of Appeals

Summary

Real estate broker Francisco Artigo sued property owners Constante and Corazon De Castro for unpaid commission balance of P303,606.24. Artigo was authorized in January 1984 to sell De Castros' Cubao properties for P23 million with 5% commission. He found Times Transit Corporation as buyer, and two lots were sold in May 1985 for actual price of P7.05 million, though deed showed P3.6 million. Artigo received only P48,893.76 partial payment but claimed full 5% commission of P352,500.00. De Castros argued other agents were involved and Artigo deserved only proportionate share. All three court levels ruled in favor of Artigo, finding valid agency contract and entitlement to full commission based on actual purchase price. Supreme Court affirmed, rejecting defenses of non-joinder of indispensable parties, full payment, and laches, while upholding awards of unpaid commission, moral damages, and attorney's fees for defendants' bad faith refusal to honor valid contractual obligation.