Eleanor Erica Strong v. Francisco Gutierrez Repide

Summary

Mrs. Strong sued to recover 800 shares of Philippine Sugar Estates Development Company stock sold by her agent Jones to defendant Repide without her knowledge. The Supreme Court affirmed recovery, ruling that Jones lacked express authority under Civil Code provisions requiring specific mandate for alienation of property. The Court rejected estoppel defenses, finding defendant failed to inquire about agent's authority despite knowing the principal's identity. Although rejecting the fraud claim and holding that corporate directors owe no fiduciary duty to individual shareholders regarding their personal stock holdings, the Court established that agents acting beyond authority create void transactions and third parties deal with agents at their own peril.