- Petitioner
- Farida Yap Bitte
- Respondent
- Spouses Fred
- Citation
- G.R. No. 212256
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Mendoza, J.
- Decided
- December 9, 2015
Summary
This case involves a property dispute over a deed of absolute sale executed by an agent after her authority was revoked. Rosa Elsa Serrano Jonas authorized her mother Andrea to sell property via Special Power of Attorney in 1985. In 1996, Spouses Bitte negotiated to buy the property through Andrea's son Cipriano and paid advances. Rosa Elsa returned from Australia and revoked the SPA on October 10, 1996, but Andrea still executed a deed of sale to Spouses Bitte on February 25, 1997. The Supreme Court held the sale unenforceable because Spouses Bitte had implied notice of the revocation when Rosa Elsa directly negotiated with them on October 11, 1996, pursuant to Article 1924 of the Civil Code. The Court also found the deed's genuineness questionable as the National Archives certified no such notarized document existed with the claimed entries. The decision affirmed the nullification of subsequent transfers and restoration of title to Rosa Elsa, emphasizing that apparent authority ends when third parties have notice of revocation and that buyers must exercise due diligence when purchasing from non-registered owners.
Intellegal Wiki · Key Holding
Denied the petition, holding the deed of sale unenforceable because the buyers had implied notice of the revocation of the agent's authority under Article 1924 when the principal dealt with them directly, and because the deed's genuineness was not established; the buyers were also not purchasers in good faith, having failed to exercise diligence in buying from non-registered owners.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.