G.R. No. 12579 - Jimenez vs. Rabot

The case involves Gregorio Jimenez (plaintiff and appellee) and Pedro Rabot (defendant and appellant), with Nicolasa Jimenez and her husband, Emilio Rodriguez, as co-defendants.
The disputed property is a parcel of land in the municipality of Alaminos, Pangasinan, described as approximately three hectares bounded by lands of Pedro Reynoso, Nicolasa Jimenez, and, on the east, lands formerly held by Calixta Apostol and later by Juan Montemayor and Simon del Barrio.

The parcel, along with two other parcels in the same locality, originally belonged to Gregorio Jimenez as an assigned share in the division of his father’s estate.
During 1911, while Gregorio resided in Vigan (Ilocos Sur), he entrusted his property in Alaminos to the care of his elder sister, Nicolasa Jimenez.

On February 7, 1911, Gregorio wrote to Nicolasa from Vigan, stating his urgent need for money to settle debts and requesting her to sell “one of my parcels of land.”
The letter did not specify a detailed description of the land to be sold but used general language to designate “one of my parcels.”
Acting on the letter, Nicolasa negotiated with Pedro Rabot, who agreed to purchase the land for the sum of P500, with an initial payment of P250 and the remaining balance to be paid upon execution of the deed.

Approximately one year after the transaction, Gregorio returned to Alaminos and demanded the return of his property from Nicolasa, who refused on pretext.
In response, Gregorio, in concert with his other siblings (owners of related parcels also in Nicolasa’s possession), instituted an action in the Court of First Instance to recover the lands.
The court rendered a favorable judgment for Gregorio and his co-owners on August 12, 1913; no appeal was filed from that judgment by them.

On May 31, 1912, Nicolasa executed and delivered to Pedro Rabot a deed purporting to convey the parcel of land in dispute.
The deed acknowledged the sale for P500 and contained a proper description of the property.
At the time of final judgment in the related action, Pedro Rabot was in possession of the property, having acquired it under the deed executed during the pendency of the litigation.

The case involves questions regarding the validity of the power of attorney (or authority) conferred by Gregorio’s letter to Nicolasa.
Relevant legal provisions include Article 1713 of the Civil Code, which requires an express mandate to alienate land, and subsection 5 of Section 335 of the Code of Civil Procedure, mandating that the agent’s authority be in writing and subscribed by the principal.
Although Nicolasa acted irregularly by conveying the property in her own name without disclosing the capacity in which she acted, her deed was argued to bind Gregorio as a contract.

Whether the power of attorney or authority conferred by Gregorio Jimenez to his sister, through the letter dated February 7, 1911, was sufficient to empower her to sell the disputed parcel of land.
Whether the absence of a detailed description in the letter affects the validity of the authority under Section 335 of the Code of Civil Procedure.

Whether the deed executed by Nicolasa Jimenez, acting under the authority granted by that letter, is binding upon Gregorio Jimenez as a valid contract.
Whether Pedro Rabot, as the purchaser who relied on the deed, could be absolved from the ensuing litigation despite the irregular mode in which the authority was exercised.

Whether the requirements of Article 1713 of the Civil Code and Section 335 of the Code of Civil Procedure have been met by the letter of February 7, 1911.
Whether established case law permitting a private document (or general power of attorney) to validly authorize the sale of real property supports the finding in this case.