Case Summary (G.R. No. 236126)
Factual Background
Eternal Gardens Memorial Park Corporation specializes in developing memorial parks and related services. The Boiser siblings, Katherine and Kathryn, are part of the heirs of Zenaida F. Boiser, who purchased 24 burial lots from Eternal Gardens, reflected in Certificate of Ownership No. 5595 issued in 1985. After Zenaida's death in 1999, it was discovered that her burial lots were sold by Michael Magpantay, Kathryn's former partner, to the Spouses Bonifacio. The Boiser siblings filed a complaint for nullification of the sales, asserting that Zenaida was deceased at the time of the transaction and alleging conspiracy between Eternal Gardens and Magpantay.
Legal Proceedings
Eternal Gardens contended that the Boiser siblings lacked a cause of action against them, as Kathryn had allegedly participated in the sale process by signing an Affidavit of Loss and confirming a Deed of Assignment in favor of Magpantay. Despite these transactions, the Regional Trial Court (RTC) found Eternal Gardens liable for not verifying the validity of the sale and that the transfer documents were invalid due to Zenaida’s death.
RTC Ruling
The RTC's ruling indicated that Eternal Gardens ratified the actions of its employees involved in the transactions. It declared the Deed of Assignment to Magpantay null and void and ordered the return of Php 2,200,000.00 to the Spouses Bonifacio, deducting the value of the burial lot used for their deceased grandchild. Eternal Gardens appealed to the Court of Appeals.
CA Ruling
The Court of Appeals upheld the RTC's decision regarding the nullity of the Deed of Assignment and imposed solidarity liability on Eternal Gardens, Magpantay, and Kathryn for the return of the purchase price. The Court ruled that the Spouses Bonifacio acted in good faith, as the certificate of ownership did not exhibit any apparent defects demanding further inquiry.
Supreme Court Decision
The Supreme Court affirmed the CA's ruling, dismissing Eternal Gardens’ arguments about the ultra vires nature of its employees' actions. The Court emphasized the principle of apparent authority, noting that by issuing a certificate of ownership based on the employees' actions, Eternal Gardens acknowledged their authority to transact on its behalf. The Court highlighted that the company could not distance itself from the liabilities incurred during the fraudulent transactions facilitated by its employees.
Liability for Damages
While the Court ruled that Eternal Gardens could not escape liability for moral and exemplary damages due to the act
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Facts of the Case
- Petitioner Eternal Gardens Memorial Park Corporation is engaged in developing memorial parks and offers memorial care products and services.
- Respondents Katherine Junette B. Perlas and Kathryn Jacquelyn F. Boiser are siblings and children of Narciso C. Boiser and Zenaida F. Boiser.
- Zenaida purchased 24 burial lots from Eternal Gardens, covered by Certificate of Ownership No. 5595, issued on June 7, 1985, before her death on September 13, 1999.
- In 2000, the Boiser siblings discovered that the burial lots were sold to spouses Claudio and Rosita Bonifacio by Michael Magpantay, Kathryn's former live-in partner.
- The Boiser siblings filed a complaint for nullification of the contract against Magpantay, Spouses Bonifacio, and Eternal Gardens, claiming Zenaida could not have sold the lots posthumously.
- Eternal Gardens responded, asserting the Boiser siblings had no cause of action and that they were aware of the Deed of Assignment in favor of Magpantay.
- The case was further complicated by the involvement of other compulsory heirs of Zenaida, who sought to intervene in the proceedings.
Regional Trial Court (RTC) Ruling
- The RTC ruled on June 13, 2013, finding Eternal Gardens liable to return the amount paid by Spouses Bonifacio, less the value of a burial lot used for their grandchild.
- The RTC held that Eternal Gardens ratified the actions of its employees by issuing a c