- Petitioner
- Sally Yoshizaki
- Respondent
- Joy Training Center of Aurora
- Citation
- G.R. No. 174978
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Brion, J.
- Decided
- July 31, 2013
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.
Intellegal Wiki · Key Holding
Affirmed the sale unenforceable, holding no valid agency to sell the realty existed since the certification was only a general power of attorney under Article 1877 while a special power under Article 1878 was required.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.