G.R. No. 15297 - tes vs. Madriguera

On July 10, 1917, defendant Anacleto Cainto, acting as agent for his principal, Damian Madriguera, purchased from plaintiff Isidro Nantes 1,257 kilos of abaca (hemp) for the sum of P1,357.56.
Only P70 was paid at the time of sale, leaving a balance of P1,287.56, as clearly set out in a written document executed on that day.

The transaction was memorialized by a written contract which specified that Cainto was acting on behalf of Madriguera, including details such as the amount of abaca, the total price, the partial payment made, and the promise to settle the balance later.
Additional evidence, including a telegram (Exhibit B) from Madriguera to Nantes and a subsequent written note by Cainto on July 16, 1917, reinforced the representation that the purchase was for Madriguera’s account.

On July 16, 1917, the full 1,257 kilos of abaca was delivered by Cainto to his codefendant Madriguera, in accordance with the agreement.
Following delivery, the plaintiff instituted legal action on August 7, 1917, to recover the remaining balance of P1,287.56 along with interest and costs.

In his answer, defendant Madriguera denied any agency relationship with Cainto, thus disclaiming any financial liability to the plaintiff.
Defendant Cainto admitted the factual allegations regarding the sale but maintained that he acted solely as Madriguera’s agent, urging that only the principal should be held liable.

The plaintiff offered key evidence including the written contract (Exhibit A), the testimony of Cainto (detailing his long-standing role as Madriguera’s buyer of abaca), as well as other witness testimonies (from Pablo Valquiera, Aniceto Caiud, and Rosendo Bagabaldoto) to establish the agency relationship.
The trial court, however, excluded several pieces of evidence (including parts of the witness testimonies and Exhibits A and B) on the ground of their alleged incompetence to prove the agency.

The trial court held that because Madriguera denied the existence of an agency relationship, no cause of action had accrued against him at the time of the complaint.
Consequently, the court rendered judgment against Cainto for the balance due while absolving Madriguera, albeit leaving open the possibility of a subsequent action by Cainto against his principal.

Whether sufficient, reliable, and competent evidence exists to establish that Anacleto Cainto was acting as an agent for Damian Madriguera in the purchase of abaca from Isidro Nantes.
Whether the documentary evidence and testimony presented (including the written contract and Cainto’s own statements) can overcome Madriguera’s categorical denial of any agency relationship.

Whether, under Article 247, a principal may be held liable on a contract entered into by his purported agent even if the principal denies the existence of an agency relationship.
Whether the plaintiff has the right to adduce proof of the agency relationship against Madriguera in an action arising from a contract executed in the principal’s name.

Whether the exclusion of testimonies and documentary exhibits prejudiced the plaintiff and erroneously shifted liability solely onto the agent, Cainto.
The propriety of the lower court’s determination that the absence of admissible proof of agency negates liability on the part of the principal.