Petitioner
Spouses Joselina Alcantara
Respondent
Brigida L. Nido
Citation
G.R. No. 165133
Court
Supreme Court
Division
Second Division
Ponente
Carpio, J.
Decided
April 19, 2010

Summary

This case involves the validity of a land sale where respondent Brigida Nido, acting as her daughter's attorney-in-fact, sold portions of unregistered land to petitioner spouses without written authority. The Supreme Court affirmed that the sale was void under Civil Code Articles 1874 and 1878, which require written authority for agents selling real property. The Court also ruled that the Regional Trial Court lacked jurisdiction since the property's assessed value of P4,890 fell within the Municipal Trial Court's exclusive jurisdiction under RA 7691. A General Power of Attorney executed in the USA was deemed inadmissible for lack of proper authentication. The decision reinforces the strict requirement of written agency authority for real estate transactions and proper jurisdictional determination based on assessed property values.

Statutes applied

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By the Intellegal Editorial Board · April 19, 2010

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