Sally Yoshizaki v. Joy Training Center of Aurora

Summary

Sally Yoshizaki challenged the Court of Appeals decision nullifying her purchase of real property from Joy Training Center through spouses Johnson as alleged agents. The Supreme Court affirmed the CA ruling, holding that no valid contract of agency existed between Joy Training and spouses Johnson to sell the real properties. The Court applied Civil Code provisions on agency, finding that TCT No. T-25334 merely indicated representation in land registration, not authority to sell. The purported board resolution and corporate secretary's certification were either inadmissible under the best evidence rule or insufficient to establish special power of attorney required for real property sales under Article 1878. The Court emphasized that persons dealing with agents must ascertain the nature and extent of the agent's authority, making Yoshizaki's purchase at her own risk. The decision reinforced that disputes involving Civil Code application on agency and property sales fall under regular courts' jurisdiction, not specialized corporate tribunals.