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GR No. 192615

2013-01-30

SPS. EUGENE L. LIM AND CONSTANCIA LIM v. CA-MINDANAO STATION

BRION, J.

BPI's subsequent execution of the SPA, however, constituted a ratification of Ramos' unauthorized representation in the collection case filed against the petitioners. A corporation can act only through natural persons duly authorized for the purpose or by a specific act of its board of directors,[17] and can also ratify the unauthorized acts of its corporate officers.[18] The act of ratification is confirmation of what its agent or delegate has done without or with insufficient authority.[19]

GR No. 166044

2012-06-18

COUNTRY BANKERS INSURANCE CORPORATION v. KEPPEL CEBU SHIPYARD

LEONARDO-DE CASTRO, J.

Under Articles 1898 and 1910, an agent's act, even if done beyond the scope of his authority, may bind the principal if he ratifies them, whether expressly or tacitly. It must be stressed though that only the principal, and not the agent, can ratify the unauthorized acts, which the principal must have knowledge of.[66] Expounding on the concept and doctrine of ratification in agency, this Court said: Ratification in agency is the adoption or confirmation by one person of an act performed on his behalf by another without authority. The substance of the doctrine is confirmation after conduct, amounting to a substitute for a prior authority. Ordinarily, the principal must have full knowledge at the time of ratification of all the material facts and circumstances relating to the unauthorized act of the person who assumed to act as agent. Thus, if material facts were suppressed or unknown, there can be no valid ratification and this regardless of the purpose or lack thereof in concealing such facts and regardless of the parties between whom the question of ratification may arise. Nevertheless, this principle does not apply if the principal's ignorance of the material facts and circumstances was willful, or that the principal chooses to act in ignorance of the facts. However, in the absence of circumstances putting a reasonably prudent man on inquiry, ratification cannot be implied as against the principal who is ignorant of the facts.[67] (Emphases supplied.)

GR No. 163825

2010-07-13

VIOLETA TUDTUD BANATE v. PHILIPPINE COUNTRYSIDE RURAL BANK

BRION, J.

It is a settled rule that persons dealing with an agent are bound at their peril, if they would hold the principal liable, to ascertain not only the fact of agency but also the nature and extent of the agent's authority, and in case either is controverted, the burden of proof is upon them to establish it.[28] As parties to the mortgage contract, the petitioners are expected to abide by its terms. The subsequent purported agreement is of no moment, and cannot prejudice PCRB, as it is beyond Mondigo's actual or apparent authority, as above discussed.

GR No. 175885

2009-02-13

ZENAIDA G. MENDOZA v. ENGR. EDUARDO PAULE

YNARES-SANTIAGO, J.

As for CRUZ, the Court of Appeals held that he knew the limits of MENDOZA's authority under the SPAs yet he still transacted with her. Citing Manila Memorial Park Cemetery, Inc. v. Linsangan,[9] the appellate court declared that the principal (PAULE) may not be bound by the acts of the agent (MENDOZA) where the third person (CRUZ) transacting with the agent knew that the latter was acting beyond the scope of her power or authority under the agency.

GR No. 159489

2008-02-04

FILIPINAS LIFE ASSURANCE COMPANY v. CLEMENTE N. PEDROSO

QUISUMBING, J.

Filipinas Life, as the principal, is liable for obligations contracted by its agent Valle. By the contract of agency, a person binds himself to render some service or to do something in representation or on behalf of another, with the consent or authority of the latter.[12] The general rule is that the principal is responsible for the acts of its agent done within the scope of its authority, and should bear the damage caused to third persons.[13] When the agent exceeds his authority, the agent becomes personally liable for the damage.[14] But even when the agent exceeds his authority, the principal is still solidarily liable together with the agent if the principal allowed the agent to act as though the agent had full powers.[15] In other words, the acts of an agent beyond the scope of his authority do not bind the principal, unless the principal ratifies them, expressly or impliedly.[16] Ratification in agency is the adoption or confirmation by one person of an act performed on his behalf by another without authority.[17]

GR NO. 150350

2006-08-22

KOJI YASUMA v. HEIRS OF CECILIO S. DE VILLA

CORONA, J.

However, the corporation may ratify the unauthorized act of its corporate officer.[12] Ratification means that the principal voluntarily adopts, confirms and gives sanction to some unauthorized act of its agent on its behalf. It is this voluntary choice, knowingly made, which amounts to a ratification of what was theretofore unauthorized and becomes the authorized act of the party so making the ratification.[13] The substance of the doctrine is confirmation after conduct, amounting to a substitute for a prior authority.[14] Ratification can be made either expressly or impliedly. Implied ratification may take various forms like silence or acquiescence, acts showing approval or adoption of the act, or acceptance and retention of benefits flowing therefrom.[15]

GR NO. 164910

2005-09-30

UNION BANK OF PHILIPPINES v. CA

YNARES-SANTIAGO, J.

Lastly, the issue of republication was never raised in the trial court or in the appellate court proceedings. It is well settled that no issue may be raised on appeal unless it has been passed upon by the lower court for consideration.[24] And where the Court of Appeals went beyond the issues of the case or where its findings of facts are conclusions without citations of specific evidence on which they are based, we are compelled to review the facts of the case.[25] We find sufficient cause to believe that the requirement of republication was duly complied with and to uphold the validity of the foreclosure sale.

GR NO. 146747

2005-08-29

MANILA ELECTRIC COMPANY v. IMPERIAL TEXTILE MILLS

CARPIO, J.

We find the appeal meritorious. While only questions of law may be raised in a petition for review under Rule 45 of the 1997 Rules of Civil Procedure, review of the lower courts' findings of fact may be granted under certain exceptions.[10] One of the exceptions is when the judgment of the appellate court is premised on a misapprehension of facts.[11] Another is when the findings of fact are premised on the supposed absence of evidence but is contradicted by the evidence on record.[12] Also, this Court may review findings of fact when the conclusion of the appellate court manifestly overlooked certain facts not disputed by the parties and which, if properly considered, would justify a different conclusion.[13]

GR No. 146747

2005-07-29

MANILA ELECTRIC COMPANY v. IMPERIAL TEXTILE MILLS

CARPIO, J.

We find the appeal meritorious. While only questions of law may be raised in a petition for review under Rule 45 of the 1997 Rules of Civil Procedure, review of the lower courts' findings of fact may be granted under certain exceptions.[10] One of the exceptions is when the judgment of the appellate court is premised on a misapprehension of facts.[11] Another is when the findings of fact are premised on the supposed absence of evidence but is contradicted by the evidence on record.[12] Also, this Court may review findings of fact when the conclusion of the appellate court manifestly overlooked certain facts not disputed by the parties and which, if properly considered, would justify a different conclusion.[13]

GR No. 156262

2005-07-14

MARIA TUAZON v. HEIRS OF BARTOLOME RAMOS

PANGANIBAN, J.

consent, express or implied, to establish the relationship; (2) the object, which is the execution of a juridical act in relation to a third person; (3) the representation, by which the one who acts as an agent does so, not for oneself, but as a representative; (4) the limitation that the agent acts within the scope of his or her authority.[10] As the basis of agency is representation, there must be, on the part of the principal, an actual intention to appoint, an intention naturally inferable from the principal's words or actions. In the same manner, there must be an intention on the part of the agent to accept the appointment and act upon it. Absent such mutual intent, there is generally no agency.[11]

	GR No. 192615 2013-01-30	SPS. EUGENE L. LIM AND CONSTANCIA LIM v. CA-MINDANAO STATION BRION, J.
BPI's subsequent execution of the SPA, however, constituted a ratification of Ramos' unauthorized representation in the collection case filed against the petitioners. A corporation can act only through natural persons duly authorized for the purpose or by a specific act of its board of directors,[17] and can also ratify the unauthorized acts of its corporate officers.[18] The act of ratification is confirmation of what its agent or delegate has done without or with insufficient authority.[19]
	GR No. 166044 2012-06-18	COUNTRY BANKERS INSURANCE CORPORATION v. KEPPEL CEBU SHIPYARD LEONARDO-DE CASTRO, J.
Under Articles 1898 and 1910, an agent's act, even if done beyond the scope of his authority, may bind the principal if he ratifies them, whether expressly or tacitly. It must be stressed though that only the principal, and not the agent, can ratify the unauthorized acts, which the principal must have knowledge of.[66] Expounding on the concept and doctrine of ratification in agency, this Court said: Ratification in agency is the adoption or confirmation by one person of an act performed on his behalf by another without authority. The substance of the doctrine is confirmation after conduct, amounting to a substitute for a prior authority. Ordinarily, the principal must have full knowledge at the time of ratification of all the material facts and circumstances relating to the unauthorized act of the person who assumed to act as agent. Thus, if material facts were suppressed or unknown, there can be no valid ratification and this regardless of the purpose or lack thereof in concealing such facts and regardless of the parties between whom the question of ratification may arise. Nevertheless, this principle does not apply if the principal's ignorance of the material facts and circumstances was willful, or that the principal chooses to act in ignorance of the facts. However, in the absence of circumstances putting a reasonably prudent man on inquiry, ratification cannot be implied as against the principal who is ignorant of the facts.[67] (Emphases supplied.)
	GR No. 163825 2010-07-13	VIOLETA TUDTUD BANATE v. PHILIPPINE COUNTRYSIDE RURAL BANK BRION, J.
It is a settled rule that persons dealing with an agent are bound at their peril, if they would hold the principal liable, to ascertain not only the fact of agency but also the nature and extent of the agent's authority, and in case either is controverted, the burden of proof is upon them to establish it.[28] As parties to the mortgage contract, the petitioners are expected to abide by its terms. The subsequent purported agreement is of no moment, and cannot prejudice PCRB, as it is beyond Mondigo's actual or apparent authority, as above discussed.
	GR No. 175885 2009-02-13	ZENAIDA G. MENDOZA v. ENGR. EDUARDO PAULE YNARES-SANTIAGO, J.
As for CRUZ, the Court of Appeals held that he knew the limits of MENDOZA's authority under the SPAs yet he still transacted with her. Citing Manila Memorial Park Cemetery, Inc. v. Linsangan,[9] the appellate court declared that the principal (PAULE) may not be bound by the acts of the agent (MENDOZA) where the third person (CRUZ) transacting with the agent knew that the latter was acting beyond the scope of her power or authority under the agency.
	GR No. 159489 2008-02-04	FILIPINAS LIFE ASSURANCE COMPANY v. CLEMENTE N. PEDROSO QUISUMBING, J.
Filipinas Life, as the principal, is liable for obligations contracted by its agent Valle. By the contract of agency, a person binds himself to render some service or to do something in representation or on behalf of another, with the consent or authority of the latter.[12] The general rule is that the principal is responsible for the acts of its agent done within the scope of its authority, and should bear the damage caused to third persons.[13] When the agent exceeds his authority, the agent becomes personally liable for the damage.[14] But even when the agent exceeds his authority, the principal is still solidarily liable together with the agent if the principal allowed the agent to act as though the agent had full powers.[15] In other words, the acts of an agent beyond the scope of his authority do not bind the principal, unless the principal ratifies them, expressly or impliedly.[16] Ratification in agency is the adoption or confirmation by one person of an act performed on his behalf by another without authority.[17]
	GR NO. 150350 2006-08-22	KOJI YASUMA v. HEIRS OF CECILIO S. DE VILLA CORONA, J.
However, the corporation may ratify the unauthorized act of its corporate officer.[12] Ratification means that the principal voluntarily adopts, confirms and gives sanction to some unauthorized act of its agent on its behalf. It is this voluntary choice, knowingly made, which amounts to a ratification of what was theretofore unauthorized and becomes the authorized act of the party so making the ratification.[13] The substance of the doctrine is confirmation after conduct, amounting to a substitute for a prior authority.[14] Ratification can be made either expressly or impliedly. Implied ratification may take various forms like silence or acquiescence, acts showing approval or adoption of the act, or acceptance and retention of benefits flowing therefrom.[15]
	GR NO. 164910 2005-09-30	UNION BANK OF PHILIPPINES v. CA YNARES-SANTIAGO, J.
Lastly, the issue of republication was never raised in the trial court or in the appellate court proceedings. It is well settled that no issue may be raised on appeal unless it has been passed upon by the lower court for consideration.[24] And where the Court of Appeals went beyond the issues of the case or where its findings of facts are conclusions without citations of specific evidence on which they are based, we are compelled to review the facts of the case.[25] We find sufficient cause to believe that the requirement of republication was duly complied with and to uphold the validity of the foreclosure sale.
	GR NO. 146747 2005-08-29	MANILA ELECTRIC COMPANY v. IMPERIAL TEXTILE MILLS CARPIO, J.
We find the appeal meritorious. While only questions of law may be raised in a petition for review under Rule 45 of the 1997 Rules of Civil Procedure, review of the lower courts' findings of fact may be granted under certain exceptions.[10] One of the exceptions is when the judgment of the appellate court is premised on a misapprehension of facts.[11] Another is when the findings of fact are premised on the supposed absence of evidence but is contradicted by the evidence on record.[12] Also, this Court may review findings of fact when the conclusion of the appellate court manifestly overlooked certain facts not disputed by the parties and which, if properly considered, would justify a different conclusion.[13]
	GR No. 146747 2005-07-29	MANILA ELECTRIC COMPANY v. IMPERIAL TEXTILE MILLS CARPIO, J.
We find the appeal meritorious. While only questions of law may be raised in a petition for review under Rule 45 of the 1997 Rules of Civil Procedure, review of the lower courts' findings of fact may be granted under certain exceptions.[10] One of the exceptions is when the judgment of the appellate court is premised on a misapprehension of facts.[11] Another is when the findings of fact are premised on the supposed absence of evidence but is contradicted by the evidence on record.[12] Also, this Court may review findings of fact when the conclusion of the appellate court manifestly overlooked certain facts not disputed by the parties and which, if properly considered, would justify a different conclusion.[13]
	GR No. 156262 2005-07-14	MARIA TUAZON v. HEIRS OF BARTOLOME RAMOS PANGANIBAN, J.
consent, express or implied, to establish the relationship; (2) the object, which is the execution of a juridical act in relation to a third person; (3) the representation, by which the one who acts as an agent does so, not for oneself, but as a representative; (4) the limitation that the agent acts within the scope of his or her authority.[10] As the basis of agency is representation, there must be, on the part of the principal, an actual intention to appoint, an intention naturally inferable from the principal's words or actions. In the same manner, there must be an intention on the part of the agent to accept the appointment and act upon it. Absent such mutual intent, there is generally no agency.[11]

MANILA MEMORIAL PARK CEMETERY v. PEDRO L. LINSANGAN