National Development Company v. Remedios Domo-Sandot

Summary

The Supreme Court denied NDC's petition and affirmed the Court of Appeals' nullification of the sale of Lot No. 263. The case centered on Article 1874 of the Civil Code, which requires written authority when an agent sells land. NDC purchased the lot from Melchor D. Estrosas, who claimed to represent the Heirs of Lucas Domo, but failed to present any written special power of attorney. The Court emphasized that mere reference to such authority in a deed of sale is insufficient - it must be offered in evidence. The decision was further supported by the fact that Melchor's family had previously sold their interest in the land, leaving him without authority or interest to sell. This case reinforces the strict requirement for written agency authorization in real property transactions and the principle that litigation must be resolved based on admissible evidence rather than presumptions.