Spouses Rolando v. Spouses Rogelio

Summary

This case involved a real estate transaction dispute where buyer-spouses Rabaja sought rescission of a contract to sell property from seller-spouses Salvador, claiming breach when sellers denied receiving P950,000.00 in payments made through their agent Gonzales. The Supreme Court affirmed the contract rescission, finding that Gonzales was properly authorized under a valid Special Power of Attorney and acted within her scope of authority per Civil Code provisions on agency. The Court upheld that when sellers failed to attend pre-trial without valid excuse, buyers could present evidence ex parte. However, the Court modified lower court rulings by removing damage awards and declining to order return of P593,400.00 garnished in a separate, final ejectment case. The decision establishes important precedents on agency authority, pre-trial procedures, and the immutability of final judgments in separate proceedings.