DOMINION INSURANCE CORPORATION v. CA

FACTS:

In this case, Rodolfo S. Guevarra brought a civil case against Dominion Insurance Corporation (Dominion) to recover the sum of P156,473.90 that he advanced as the manager of Dominion to settle claims by Dominion's clients. Dominion denied any responsibility and counterclaimed for P249,672.53 in alleged unremitted premiums. Dominion also filed a third-party complaint against Fernando Austria, the Regional Manager for Central Luzon during that time.

Multiple pre-trial conferences were scheduled but frequently postponed upon joint request of the parties. On one scheduled pre-trial conference, only Guevarra and his counsel attended, as Dominion and its counsel did not appear. Guevarra objected to the desired postponement, moved to have Dominion declared in default, and the trial court granted the motion. Guevarra presented evidence and filed offers of documentary exhibits. Later, Dominion filed a motion to lift the order of default, but it was denied.

The trial court ultimately ruled in favor of Guevarra, ordering Dominion to pay him the amount advanced for settling Dominion's clients' claims and attorney's fees. Dominion appealed the decision to the Court of Appeals, which affirmed the trial court's ruling. Dominion then filed a motion for reconsideration, which was subsequently denied. Consequently, Dominion filed the present appeal.

The main issues raised in this case are whether Guevarra acted within his authority as Dominion's agent and whether he is entitled to be reimbursed for the amounts he personally paid to settle claims made by several insured individuals.

ISSUES:

  1. Whether respondent Guevarra acted within his authority as agent for petitioner.

  2. Whether respondent Guevarra is entitled to reimbursement of amounts he paid out of his personal money in settling the claims of several insured.

RULING:

  1. The petition is without merit.

PRINCIPLES:

  • 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. The basis for agency is representation. On the part of the principal, there must be an actual intention to appoint or an intention naturally inferable from his words or actions, while on the part of the agent, there must be an acceptance and an intention to perform the task.

  • The evidence sufficiently establishes that respondent acted within his authority as agent. He was authorized to pay off the claims of Dominion's clients and was given discretion in assessing the clients' claims and making the necessary settlements.

  • An agent who pays a debt of his principal without any instructions to do so, using his own funds, has the right to reimbursement from the principal. This is based on the principle that no person should be allowed to enrich himself at the expense of another.