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JOSE BORDADOR v. BRIGIDA D. LUZ

FACTS:

The petitioners, engaged in the jewelry business, alleged that the respondent Deganos received various pieces of gold and jewelry from them with the understanding that he would sell them and remit the proceeds. However, Deganos only remitted a portion of the proceeds and failed to return the unsold items. The petitioners filed a complaint against Deganos and Brigida D. Luz in the RTC seeking recovery of money and damages. The RTC found Deganos liable but absolved Brigida and her spouse of liability. The CA affirmed the RTC's decision and denied the petitioners' motion for reconsideration. The petitioners filed a petition for certiorari with the Supreme Court.

The primary issue in the case is whether the respondent spouses are liable for the petitioners' claim. The petitioners argued that Deganos acted as the agent of Brigida, making her solidarily liable with him. They cited letters from Brigida acknowledging her obligation and her admission that Deganos delivered gold to her as evidence of their agency relationship. However, both the trial court and the CA found that the letters were not related to the money being sought in the current case and that Brigida did not admit liability for the specific items involved. The CA ruled that Brigida never authorized Deganos to act on her behalf in any transaction with the petitioners. The Supreme Court found no evidence to support the theory that Deganos was Brigida's agent and concluded that she is not liable for his obligations.

ISSUES:

  1. Issue: Whether or not respondent spouses Brigida D. Luz and Ernesto M. Luz are liable to petitioners for the amount of P725,463.98, plus interests and attorney's fees, despite the lack of evidence showing their authorization of Narciso Deganos to receive the jewelry on their behalf.

  2. Issue: Whether the decision of the Court of Appeals in favor of respondent spouses contradicts a previous appellate ruling in a related criminal case, leading to a possible conflict of decisions.

  3. Issue: Whether the Court of Appeals acted irregularly or fraudulently in issuing its denial resolution on the motion for reconsideration.

  4. Issue: Whether the alleged contract of agency between Brigida D. Luz and Narciso Deganos falls under the Statute of Frauds and is thereby unenforceable.

RULING:

  1. Ruling: The respondent spouses Brigida D. Luz and Ernesto M. Luz are not liable to the petitioners for the amount claimed. The evidence does not support the theory that Narciso Deganos acted as the agent of Brigida D. Luz with her authorization regarding the jewelry transactions.

  2. Ruling: There is no conflict between the civil case and the pending criminal case. The civil case may proceed independently under Article 33 of the Civil Code, and the quantum of proof required in civil and criminal cases differs.

  3. Ruling: There were no irregularities or fraud committed by the Court of Appeals in issuing its denial resolution. The resolution was issued appropriately considering the reply by the petitioners, and official duties are presumed to be regularly performed.

  4. Ruling: The trial court did not err in ruling that even if there was a contract of agency, it would be unenforceable under the Statute of Frauds without a note or memorandum. However, it was ultimately concluded that no such agency or delivery of items to Brigida D. Luz occurred.

PRINCIPLES:

  1. Civil Code, Article 1868: Agency requires consent or authority from the principal.

  2. Preponderance of Evidence: A civil action for damages based on fraud can proceed independently of a criminal case and requires a lower standard of proof.

  3. Statute of Frauds: Certain contracts, including agency, require a written note or memorandum to be enforceable.

  4. Presumption of Regularity in Official Acts: Judicial and official acts are presumed to be done in regular and proper manner unless proven otherwise.

  5. Independent Proceeding of Civil and Criminal Cases: A civil action for damages can proceed separately and independently from a related criminal prosecution.