MANOTOK BROTHERS v. CA

FACTS:

In this case, the petitioner, Manotok Brothers, Inc., filed a Petition seeking relief from the Court's Resolution dismissing their case. They also requested a preliminary injunction and argued that the respondent, Salvador Saligumba, should be held in contempt for depriving them of their right to due process.

The case revolves around a parcel of land and building owned by the petitioner. It was previously leased by the City of Manila and used by Claro M. Recto High School. The petitioner authorized the respondent to negotiate the sale of the property to the City of Manila, with a commission of 5% if the sale was consummated.

Several letters were exchanged between the petitioner and respondent, extending the respondent's authority to negotiate. Eventually, the sale was approved by the Municipal Board of the City of Manila. However, the petitioner refused to pay the commission to the respondent, claiming that he was not the person responsible for the negotiation and consummation of the sale.

In response, the respondent filed a complaint against the petitioner, alleging that he successfully negotiated the sale. The trial ensued, with testimonies from both parties and other witnesses confirming the authority of the respondent and his efforts to ensure the sale was consummated.

During the trial, the petitioner's witnesses testified to an agreement between the petitioner's president and another person regarding a "gratification" if the sale was expedited.

ISSUES:

  1. Whether or not private respondent is entitled to the agent's commission.

  2. Whether or not the expiration of the agent's authority affects his entitlement to commission.

  3. Whether the private respondent is entitled to a commission.

  4. Whether the case of Danon vs. Brimo applies to the instant petition.

RULING:

  1. Private respondent is entitled to the agent's commission.

  2. The expiration of the agent's authority does not affect his entitlement to commission.

  3. The private respondent is entitled to a commission. The Court held that when there is a close, proximate and causal connection between the agent's efforts and labor and the principal's sale of his property, the agent is entitled to a commission. In this case, the private respondent was the efficient procuring cause for the sale of the property to the City of Manila. Even though his authority had already expired at the time of the sale, the approval of the sale came only three days after the expiration of his authority. Furthermore, the private respondent was the only one given written authority by the petitioner to negotiate the sale during the relevant period.

  4. The case of Danon vs. Brimo does not apply to the instant petition. In Danon, the claimant-agent was informed that another agent was also negotiating the sale and that compensation would pertain to the one who finds a purchaser and eventually effects the sale. This is not the case here as the private respondent pursued the negotiations believing that he alone was transacting the business with the City Government.

PRINCIPLES:

  • A broker or agent is not entitled to any commission until he has successfully brought the parties to a transaction together.

  • However, there is an exception to this rule. In the case of Prats vs. Court of Appeals, it was held that even if the agent's authority has expired, he may still be entitled to compensation if he was instrumental in bringing the parties together and the sale was eventually consummated.

  • The determination of entitlement to commission in such cases is based on equity.

  • When there is a close, proximate and causal connection between the agent's efforts and labor and the principal's sale of his property, the agent is entitled to a commission.

  • The case of Danon vs. Brimo does not apply when the claimant-agent believes that he alone is transacting the business and is not informed of other agents negotiating the sale.