Agency Coupled with Interest:

But unlike simple grants of a power of attorney, the agency that we

hereby declare to be compatible with the intent of the parties, cannot be
revoked at will. The reason is that it is one coupled with an interest, the
agency having been created for the mutual interest of the agent and the
principal. It is an agency that, as we said, cannot be revoked at the
pleasure of the principal. (Sevilla v CA, 1988)

However, an exception to the revocability of a contract of agency is

when it is coupled with interest, i.e., if a bilateral contract depends upon
the agency. The reason for its irrevocability is because the agency be-
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comes part of another obligation or agreement. It is not solely the rights

of the principal but also that of the agent and third persons which are af-
fected. Hence, the law provides that in such cases, the agency cannot be
revoked at the sole will of the principal. (Republic v Evangelista, 2005)