Carlos Sanchez v. Medicard Philippines

Summary

Carlos Sanchez, special corporate agent of Medicard Philippines, Inc., successfully procured two consecutive health care contracts with Unilab, earning substantial commissions. When Unilab rejected a premium increase for the third year, Medicard asked Sanchez to reduce his commission, which he refused. Unilab terminated the original contract but negotiated directly with Medicard for a new 'cost plus' arrangement, bypassing Sanchez. The Supreme Court held that Medicard properly revoked the agency under Article 1924 of the Civil Code when it directly managed the business. Since Sanchez was not the procuring cause of the new contract and his refusal to compromise led to direct negotiations between the parties, he was not entitled to commission under the new arrangement.