Case Digest (G.R. No. 76969)
Facts:
In Inland Realty Investment Service, Inc. and Roman M. de los Reyes vs. Hon. Court of Appeals, Gregorio Araneta, Inc. and J. Armando Eduque, G.R. No. 76969, decided on June 9, 1997, petitioners Inland Realty Investment Service, Inc. and its broker Roman M. de los Reyes entered into an agency contract with private respondent Gregorio Araneta, Inc., through its Assistant General Manager J. Armando Eduque, on September 16, 1975. They were authorized for thirty days to sell 9,800 shares of Architects’ Building, Inc. at P1,500 per share. This authority was renewed on October 2, October 28 and December 2, 1975 (Exhibits “J,” “L,” “K”). Petitioners introduced Stanford Microsystems, Inc. as a prospective buyer, which counter‐offered P1,000 per share with terms payable over five years at 12% interest. Defendants suggested improving the offer, but petitioners failed to produce any proof of valid renewals beyond January 1, 1976. On July 8, 1977, Stanford acquired the shares for P13,500,000Case Digest (G.R. No. 76969)
Facts:
- Origin and terms of the agency
- On September 16, 1975, Gregorio Araneta, Inc. (through its Asst. GM J. Armando Eduque) granted Inland Realty Investment Service, Inc. (represented by Roman M. de los Reyes) a 30-day authority to sell 9,800 shares of Architects’ Bldg., Inc. at ₱1,500/share.
- Inland Realty, a licensed real estate broker, began marketing, sending proposal letters to prospective buyers, including Stanford Microsystems, Inc.
- Counter-proposal and extensions
- Stanford counter-offered ₱1,000/share (₱9.8 M total), 50% payable over five years at 12% p.a.; Inland Realty registered Stanford as a buyer.
- Araneta, Inc. deemed the price too low and urged improved terms. Other buyers (Atty. Belmonte, Joselito Hernandez) were likewise submitted.
- The sale authority was extended thrice by letters:
- October 2, 1975 – 30 days (Exh. “J”)
- October 28, 1975 – 30 days (Exh. “L”)
- December 2, 1975 – 30 days (Exh. “K”)
- The last extension expired January 1, 1976.
- Consummation of sale and demand for commission
- On July 8, 1977, Araneta, Inc. sold the 9,800 shares to Stanford for ₱13.5 M.
- On September 6, 1977, petitioners demanded a 5% commission (₱675,000), which respondents refused.
- Proceedings below
- Trial court dismissed petitioners’ complaint, holding their authority expired January 1, 1976, and they were not involved in the eventual sale.
- The Court of Appeals affirmed: no valid extension past December 2, 1975; 1 year 5 months lapsed without communication or negotiation; petitioners not efficient procuring cause.
Issues:
- Did petitioners prove a valid extension of their agency beyond January 1, 1976 via Exhibits “L” (Oct. 28, 1976) and “M” (Nov. 16, 1976)?
- Is a broker automatically entitled to the stipulated commission upon introducing the buyer who ultimately purchases, regardless of agency expiration?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)