Republic of the Philippines v. Hon. Victorino Evangelista

Summary

The Supreme Court upheld the validity of an agency coupled with interest in a treasure hunting dispute. Dante Legaspi owned land where military officials conducted treasure hunting operations pursuant to an agreement with a third party. Legaspi's nephew Gutierrez, appointed as attorney-in-fact with 40% interest in any treasure found, sued for damages and injunction. When Legaspi attempted to revoke the agency, the Court ruled it irrevocable because it was coupled with interest - Gutierrez had financial stake in the treasure and had contracted with lawyers for services based on treasure shares. The Court affirmed the preliminary injunction protecting Legaspi's property rights and rejected claims of judicial bias. This case establishes important precedent on irrevocable agencies under Civil Code Art. 1927 and reinforces property owners' rights to seek injunctive relief against unauthorized activities on their land.