ISSUE:

GONZALES-SALDANA v. SPOUSES NIAMATALI Whether or not Gonzales acted beyond her scope of authority by purchasing
Nov. 21, 2018 | J.C. Reyes, Jr. | When act beyond the scope of agent’s
authority: unenforceable, not void, unless principal ratifies which makes it
valid (1898)
FACTS:
Respondent spouses Gordon and Amy Niamatali (who were in the US at this
time) told petitioner Donabelle Gonzales-Saldana their intention to acquire
real properties in Metro Manila. Working in the DOLE, she informed them
that there was a land in Las Piñas to be sold in a public auction. So the
spouses asked Gonzales to participate in the action and remitted to her bank
account 3 million pesos for the purchase of the property. However,
subsequently, the spouses received TCTs covering properties in Manila and
Parañaque, contrary to agreement that Gonzales will purchase Las Piñas
property. Gonzales reasoned that the public auction didn’t push through
because of a third party claim, but the judgement creditor agreed to sell her
Paranaque and Manila properties.
the Manila and Paranaque properties?
RULING: Yes.
1. There was an implied agency between the petitioner and
respondent-spouses.
2. An agency is inferred from all the dealings between the parties.
3. Gonzales though acted beyond her scope of authority. When the
parties came to an agreement to purchase Las Pinas property,
Gonzales was then unaware of other properties which were going
to be sold in the auction. As a result, the parties never agreed on a
substitute property. Thus even though petitioner may have been
motivated by good intentions and by sincere belief that the
purchase of the Manila and Paranaque properties would benefit the
spouses, it was still outside her authority.
4. Hence, petitioner failure to fulfill her obligation entitles spouses to
the return of the 3M which they remitted to her account.

When spouses returned to the PH, Gonzales brought them to Las Pinas
property and showed that it was locked up with a signboard saying Future
Home of Lutheran School and Community Center. Spouses then said they
didn’t want the Las Pinas property anymore and asked for the return of the
3M. Gonzales agreed and sent a letter to the spouses saying that she received
the 3M and would return it before Sept. 14, 2002.

Gonzales avers that she asked the spouses if they were interested in buying
the Manila and Paranaque property, but the spouses didn’t respond. So in
good faith, thinking it was beneficial for the spouses, Gonzales purchased
the Manila and Paranaque properties through winning it in an auction which
she asked her friend, Austria, to participate in. Despite several demands from
the spouses, Gonzales failed to remit the 3M.

RTC ruled in favor Gonzales, saying that that the documentary evidence of
the spouses failed to comply with Best Evidence Rule, and that the
uncertificated photocopies of bank transfer were inadmissible. The CA ruled
in favor of the respondent spouses, saying that since the petitioner admitted
to having received the 3M, it was sufficient evidence to prove that she
received the money, even without documents presented by the respondent-
spouses.

Agency Coch Digests | Baccay 16