FACTS:
Petitioners Inland Realty Investment Service, Inc. and Roman M. de los Reyes filed an appeal to the Intermediate Appellate Court regarding the dismissal of their claim for unpaid agent's commission. The claim was in relation to a sales transaction involving 9,800 shares of stock in Architects' Bldg., Inc., with the seller being private respondent Gregorio Araneta, Inc. and the buyer being Stanford Microsystems, Inc.
The petitioners argue that the lower courts erred in disregarding their authority to act as sales agent, which they claim is evidenced by Letter "L" and Letter "M". They also assert that a broker is entitled to a commission when introducing the buyer to the seller, regardless of the expiration of their contract.
According to the undisputed facts, the defendant corporation granted the plaintiffs a 30-day authority to sell the shares of stock. Inland Realty, a licensed real estate business engaged in brokerages, formulated a sales campaign and sent proposal letters to potential buyers. Stanford Microsystems, Inc., one of the prospective buyers, countered by offering to purchase the shares at a lower price. Plaintiffs registered Stanford as a prospective buyer, and defendant Araneta, Inc. replied that the price offered was too low, suggesting improvements to the price and terms of payment. The authority to sell was extended multiple times.
Eventually, the plaintiffs sold the shares to Stanford Microsystems, Inc. and subsequently demanded the payment of their commission. However, defendants rejected the claim, arguing that the commission had no factual or legal basis to be granted. The trial court dismissed the plaintiff's complaint for unpaid commission, and the Court of Appeals affirmed this decision.
ISSUES:
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Whether the trial court and appellate court erred in disregarding Exhibits "L" and "M."
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Whether a broker is entitled to the stipulated commission even after the expiration of the broker's contract and authority to sell.
RULING:
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The trial court and appellate court did not err in disregarding Exhibits "L" and "M" since they were not included as evidence in the case.
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A broker is not automatically entitled to the stipulated commission upon the expiration of the broker's contract and authority to sell. The consummation of the sale must occur within the duration of the broker's authority for the broker to be entitled to the commission.
PRINCIPLES:
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Evidence not presented in court cannot be considered by the court in rendering its decision.
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A broker's entitlement to commission is contingent upon the consummation of the sale within the duration of the broker's authority.