Case Summary (G.R. No. 129039)
Applicable Law
This case is governed by the 1987 Philippine Constitution, along with relevant provisions from the Civil Code of the Philippines that pertain to agency, contracts, and rights of parties involved in contractual obligations.
Overview of the Dispute
At the heart of the dispute lies a contractual relationship concerning the construction of residential units in Ysmael Village. Conrado De Guzman entered into a Deed of Agreement with Hermogenes B. Santos, purportedly representing Siredy Enterprises, Inc., to construct housing units. The issue arose when De Guzman sought to collect unpaid amounts for 13 residential units he constructed, totaling P412,154.93, after only partial payment had been made for the units.
Petition for Review Background
Siredy Enterprises sought to annul the April 26, 1996, decision of the Court of Appeals, which reversed the ruling of the Regional Trial Court of Malolos, Bulacan favoring Siredy, and affirmed De Guzman's claim for damages. The petitioner argued that they had no binding contract with De Guzman and denied the authority of Santos as an agent to enter into the Deed of Agreement.
Findings of the Court of Appeals
The Court of Appeals held that the Letter of Authority signed by Ismael Yanga constituted Santos as Siredy's authorized agent, thereby granting him the authority to enter into the contract for the construction of the housing units. The appellate court found that it was unnecessary for Yanga to sign the contract himself for Siredy to be liable for the terms of the agreement executed by Santos.
Agency and Contractual Authority
Central to the court's analysis was the determination of whether Santos acted within the scope of his authority as Siredy’s agent. The court examined the Letter of Authority and noted that it explicitly permitted Santos to negotiate and enter into contracts for building housing units. The court emphasized that the agency relationship allowed third parties, like De Guzman, to presume that Santos had the appropriate authority to bind Siredy, even if actual internal corporate practices differed.
Importance of Documentary Evidence
The court underscored the weight of the documentary evidence, including Siredy’s Articles of Incorporation, which allowed the company to conduct business involving the erection and sale of residential structures. Despite Siredy’s claims that they primarily sold vacant lots and had no capability to undertake construction, the court found that their own documentation contradicted such assertions and might support De Guzman's claims for damages.
Final Ruling and Liability
In concluding its analysis, the Supreme Court upheld the Court of Appeals' ruling, confirmin
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Case Background
- The case involves a petition for review seeking to annul the decision of the Court of Appeals dated April 26, 1996, which reversed the ruling of the Regional Trial Court (RTC) in Malolos, Bulacan.
- The Court of Appeals ruled in favor of private respondent Conrado De Guzman against petitioner Siredy Enterprises, Inc., and its president Ismael E. Yanga.
- The RTC had previously dismissed De Guzman's claims against Siredy and Yanga, holding that there was no contractual relationship between them.
Parties Involved
- Petitioner: Siredy Enterprises, Inc., a corporation engaged in land development and housing construction, represented by its president Ismael E. Yanga.
- Respondent: Conrado De Guzman, an architect-contractor operating under the name Jigscon Construction.
Facts of the Case
- Prior to October 1978, Yanga executed a Letter of Authority designating Hermogenes B. Santos as an authorized representative to negotiate and enter into contracts for building housing units.
- On October 15, 1978, Santos entered into a Deed of Agreement with De Guzman to construct residential units at Ysmael Village for a total price of P4,842,000.00.
- De Guzman constructed 26 residential units, of which 13 were fully paid, and 13 remained unpaid, totaling P412,154.93 owed.
- De Guzman unsuccessfully attempted to collect the unpaid amount from Siredy, leading to a lawsuit for specific performance.
Trial Court's Decision
- The RTC ruled in favor of Siredy Enterprises, stating that Siredy was not a party to the Deed of Agreement, and theref