Paz S. Lim For Herself v. Victoria K. Chan

Summary

This case involves a property dispute where petitioner Paz Lim sought to annul property sales executed by her attorneys-in-fact, claiming fraud and breach of fiduciary duty. In 1973, Lim appointed Carlos Chan and Victor San as attorneys-in-fact over several properties. These agents subsequently executed deeds of sale transferring the properties to Victoria Chan between 1975-1978. Twenty years later, Lim filed suit claiming the transfers were fraudulent and that agents cannot acquire their principal's property. Both the trial court and Court of Appeals dismissed the case on procedural grounds including prescription and estoppel. The Supreme Court reversed, emphasizing that issues of fraud, estoppel, and prescription require full trial on the merits rather than summary dismissal. The Court reinforced the Civil Code principle prohibiting agents from acquiring their principal's property and ruled that actions to recover such property are imprescriptible. The case was remanded for proper trial, highlighting the importance of due process in complex property disputes involving fiduciary relationships.