G.R. No. 13471 - Sy Juco vs. Sy Juco

In 1902, the defendant was appointed by his plaintiffs (his father and mother) as the administrator of their properties.
He acted in that capacity until June 30, 1916, when his authority was cancelled.

In July 1914, the defendant purchased the launch in his own name from the Pacific Commercial Co.
Despite the purchase and subsequent registration at the Custom House in his name, the plaintiffs allege that the funds used were theirs and that the purchase fell within his agency, violating his duty to act in their behalf.
Additional evidence, such as the prompt repairs with expenses charged to the plaintiffs, supports the claim that the money used for the purchase belonged to the plaintiffs.

The defendant claims that the casco was constructed at his instance and with his own funds.
Contrarily, the plaintiffs contend and provide testimony that the casco was built by the plaintiffs themselves, implying that it was financed with their money.
The evidence, including the defendant’s inability to have funds available during construction, supports the plaintiffs’ position.

The defendant asserts that it was purchased with his own money.
However, evidence regarding bank deposits and check issuances indicates that the payment for the automobile was made with the plaintiffs’ funds, despite the defendant’s attempt to suggest otherwise.

The trial court rendered a decision largely in favor of the plaintiffs, directing the defendant to:

Return the launch Malabon, execute necessary documents, and have it registered in the plaintiffs’ name at the Custom House.
Return Casco No. 2584 or pay its appraised value of P3,000, with corresponding registration documents if returned.
Return the automobile No. 2060 and execute the necessary registration instruments at the Bureau of Public Works.

Rendering accounts of his administration of the plaintiffs’ property.
The return of Casco No. 2545, a typewriting machine, the house he occupied, and the price of a piano.

Both parties appealed the decision with various allegations of error regarding the treatment of certain assets and obligations.

The defendant pointed out errors with respect to the items unfavorable to him (launch, casco No. 2584, automobile) asserting that he had acted within the scope of his authority.
The plaintiffs also raised issues concerning:

The proper ownership of Casco No. 2545, which was leased and later sunk.
The obligation to render a full account of the administration.
The valuation and ownership of woods, windows, and doors used in the construction of a house on calle Real in La Concepcion, Malabon, Rizal.

Whether the defendant’s purchase of the launch Malabon in his own name, using the plaintiffs’ funds during his term as agent, constitutes a violation of his agency duty to act solely for the plaintiffs’ benefit.
Whether the act of registering the property in his own name by the defendant affects the ownership rights of the plaintiffs given that the purchase was allegedly made with their money.

Whether the evidence, such as the immediate repairs and the bank deposit transactions, conclusively demonstrates that the funds used to purchase the launch, casco No. 2584, and automobile No. 2060 were the plaintiffs’ funds, not the defendant’s own.
Whether the defendant’s own testimony and documents sufficiently substantiate his claim that he acted with his own funds in the transactions.

Whether the rule under Article 1717 of the Civil Code, with its exception in cases dealing with things belonging to the principal, applies to render the transaction between the defendant and the vendor as effectively one between the plaintiffs and the vendor.
The implications of such an interpretation on the transfer of property rights from the defendant to the plaintiffs.

The proper ownership and disposition of Casco No. 2545 given its leased status and subsequent sinking.
The correctness of absolving the defendant from rendering a complete account of his administration in light of the plaintiffs’ evidence that he rendered accounts periodically to their satisfaction.
The responsibility for the woods, windows, and doors used in the construction of the house and whether these should be considered the defendant’s property or that of the plaintiffs.