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SYLVIA H. BEDIA v. EMILY A. WHITE

FACTS:

The case involves a dispute between petitioner Sylvia H. Bedia and private respondent Emily A. White regarding the capacity in which Bedia entered into a Participation Contract with White for the 1980 Dallas State Fair in Texas. Bedia insists that she was acting as an agent, while White claims that Bedia deceived her and violated their agreement. In her complaint, White alleged that Bedia convinced her to participate in the fair and that she made a down payment of $500.00 to Bedia for the display space. However, upon arriving at the fair, White discovered that Bedia had not registered any display space in her name and had not paid for it. White filed a complaint for damages against Bedia and Hontiveros & Associated Producers Phil. Yields, Inc. The trial court held Bedia liable for fraud and awarded damages to White. Bedia appealed the decision, arguing that she was acting as an agent and therefore should not be held personally liable for the obligations under the contract.

ISSUES:

  1. Whether petitioner Sylvia H. Bedia entered into the contract as an agent or in her personal capacity.

  2. Whether Bedia should be held liable for damages caused by the fraudulent violation of the agreement.

RULING:

  1. The Supreme Court reversed the lower courts' finding that Bedia entered into the contract in her personal capacity. The court held that Bedia acted as an agent for Hontiveros & Associated Producers Phil. Yields, Inc. This is supported by the fact that the Participation Contract was signed by Bedia and the acknowledgment made by Emily White in a letter that Bedia recruited her as a participant on behalf of Hontiveros. Hontiveros itself did not repudiate Bedia's agency and filed a joint answer with Bedia, affirming her agency. Therefore, Bedia should not be held personally liable for the obligations arising from the agreement.

  2. The plaintiffs' complaint for damages against Bedia was dismissed since she acted as an agent and the obligation arising from the agreement was imputable to Hontiveros. The plaintiffs' motion to dismiss the complaint against Hontiveros left them without a cause of action against Bedia for Hontiveros' obligations. The plaintiffs waived their claims against the principal and cannot assert them against the agent.

PRINCIPLES:

  • One cannot contract in the name of another without authority, unless there is a legal right to represent the other party (Article 1347, new Civil Code).

  • If an agent acts in his own name, the principal has no right of action against the persons with whom the agent had contracted (Article 1883, new Civil Code).

  • The principal must comply with all the obligations which the agent may have contracted within the scope of his authority (Article 1910, Civil Code).