Title
Caoile vs. Court of Appeals
Case
G.R. No. 106929
Decision Date
Sep 21, 1993
Soledad paid P120,000 for a lot sold by Anita Caoile, who lacked authority. Gatchalian, signing as "agent," was not liable; only Caoile was held accountable for the fraud.
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Case Digest (G.R. No. 106929)

Facts:

Background of the Transaction

  • In January 1986, Soledad de Jesus expressed her interest in buying a residential lot to Erlinda Domingo, a resident of Sterling Life Homes, Las PiƱas.
  • Domingo informed Erlinda Gatchalian, her "kumadre," about Soledad's interest. Gatchalian mentioned a lot for sale in the subdivision.
  • Soledad, accompanied by Domingo, Gatchalian, and Tess Tameta, inspected Lot No. 5, Block 8, and decided to purchase it.

Payment and Receipts

  • Soledad met Anita Caoile, Chief Accountant and Assistant Vice-President of Sterling Life Assurance Corporation, who assured her the lot was for sale.
  • On February 3, 1986, Soledad paid a deposit of P10,000.00, evidenced by a receipt signed by Anita Caoile as "agent."
  • On February 5, 1986, Soledad paid P61,000.00, with a receipt signed by Anita Caoile and Erlinda Gatchalian as "agents."
  • On March 18, 1986, Soledad paid P39,000.00, and on March 21, 1986, she paid the balance of P10,000.00. Anita Caoile issued a consolidated receipt for the total payment of P120,000.00.

Discovery of Fraud

  • After full payment, Soledad demanded the Deed of Sale and Transfer Certificate of Title, but Anita Caoile failed to deliver.
  • Soledad discovered that Anita was not authorized to sell the lot, which had already been sold to Ruben Rodis in 1977.
  • Anita had been forced to resign from Sterling Life Assurance Corporation due to anomalies and had not been reporting for work since May 1986.

Legal Proceedings

  • Soledad filed a complaint for a sum of money against Anita Caoile, Erlinda Domingo, Erlinda Gatchalian, and Sterling Life Assurance Corporation.
  • The trial court held Anita Caoile liable for P120,000.00 but dismissed the complaint against Domingo, Gatchalian, and Sterling Life Assurance Corporation.
  • The Court of Appeals modified the decision, holding Gatchalian jointly and severally liable with Anita Caoile for P61,000.00.

Issue:

  1. Whether Erlinda Gatchalian is jointly and severally liable with Anita Caoile for the amount of P61,000.00 based on the receipt she signed as "agent."
  2. Whether the Court of Appeals erred in holding Gatchalian liable despite the trial court's findings that she did not receive any commission or amount from the transaction.

Ruling:

The Supreme Court granted the petition and set aside the decision of the Court of Appeals. The trial court's decision was reinstated, holding only Anita Caoile liable for the amount of P120,000.00. Erlinda Gatchalian was not held solidarily liable with Anita Caoile.

Ratio:

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