- Petitioner
- Eurotech Industrial Technologies
- Respondent
- Edwin Cuizon
- Citation
- G.R. No. 167552
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Chico-Nazario, J.
- Decided
- April 23, 2007
Summary
Eurotech Industrial Technologies sued both Cuizon brothers over unpaid obligations from equipment sales totaling P295,000.00. Edwin Cuizon, sales manager of Impact Systems Sales (owned by his brother Erwin), had signed a Deed of Assignment of receivables to secure payment for a sludge pump. Edwin moved to be dropped as defendant, claiming he was merely an agent. The Supreme Court affirmed lower courts' rulings dropping Edwin, holding that as sales manager, he acted within his broad authority when signing the assignment. Under Civil Code Article 1897, agents are not personally liable unless they exceed authority or expressly bind themselves. Since Edwin acted to protect his principal's business interests and within his managerial scope, he was not a real party in interest. The case establishes important precedent on agency law and the authority limits of business managers in commercial transactions.