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Angeles v.

PNR
G.R. No. 150128 August 31, 2006 Garcia, J.
petitioners Laureano T. Angeles
respondents Philippine National Railways and Rodolfo Flores
summary Romualdez (principal) bought PNRs scrap rails and wrote a letter to the latter informing it that
Lizette (agent) is his lawful representative in the withdrawal of the rails he bought. PNR
suspended the withdrawal and refused to refund the purchase price when demanded by Lizette.
Is Lizette Romualdezs agent or assignee? Agent. See Doctrine below.

facts of the case


PNR informed Romualdez that it accepted the latters offer to buy on an AS IS, WHERE IS basis, the PNRs
scrap/unserviceable rails in Del Carmen (P1.3k per metric ton) and Lubao, Pampanga (P2.1k per metric ton) for P96.6k.
Romualdez then wrote a letter to Atty Dizon, PNRs Acting Purchasing Agent, (after paying) informing him that Lizette
(wife of Laureano) is his lawful representative in the withdrawal of the scrap/unserviceable rails he bought. Lizette later
requested a transfer in the location of the withdrawal (rails werent ready for hauling)which was granted by the PNR
(moved to Capas and Tarlac). Subsequently, PNR suspended the withdrawal (cause: documentary discrepancies +
pilferages of P500k worth of PNR scrap properties in Tarlac).

Sps Angeles demanded a refund of the P96k but PNR refused (54.659 metric tons were
already withdrawn (delivery receipt signed by wife) which amounts to more than what they paid
(P114k.7k)) so the former filed a case for specific performance and damages against PNR with
the RTC QC (deliver 46 metric tons + pay dmgs and attys fees).

TC: (while case was pending, Lizette died & was substituted by husband Laureano & heirs)
dismissed complaint. Sps Angeles arent real parties-in-interest cos Lizettes merely a
Romualdezs representative and not an assignee to the latters rights with respect to the award.
Laureano appealed to CA which dismissed the case and later denied formers MR.

issue
WoN CA erred in affirming TCs holding that Sps Angeles, as plaintiffs a quo, had no cause of action as they werent real
parties-in-interest in this case. NO. CA was correct. Lizette has no legal standing (hence husband also has no standing)
Whether Romualdezs letter designated Lizette as an agent or as an assignee. Agent.

ratio
Doctrine: Where agency exists, the 3rd partys (PNRs) liability on a contract is to the principal (Romualdez) and not to the
agent (Lizette) and the relationship of the 3rd party to the principal is the same as that in contract in which theres no
agent.
GR: an agent has neither rights nor liabilities as against a 3rd party (cos only contracting parties may violate the
contract)
E: when the agent is constituted as an assignee. In such case, the agent may, in his own behalf, sue on a contract
made for his principal (rule requiring every action to be prosecuted in the name of the real party-in-interest
recognizes the assignment of rights).

The letter1 shows that Lizette was to act just as a representative and not an assignee. This means that her husband, as her
conjugal partner/heir, also doesn't have standing.
Petitioner argues that agent/atty-in-fact werent used in Romualdezs letter. The Ct said that the words
principal and agent arent the only terms used to designate the parties in an agency relation.
The use of authorized instead of assigned in the letter indicated Romualdezs intent to limit Lizettes role
in the scrap transaction to being the representative of his interest therein.
For this reason conveys the idea that Lizette was given the original copy of the contract award to enable her
to withdraw the rails as Romualdezs authorized representative. Art. 1374 CC provides that various stipns of a

1 Dear Atty Dizon: This is to inform you as President of San Juanico Enterprises, that I have authorized the bearer, LIZETTE R.
WIJANCO of No. 1606 Aragon St., Sta. Cruz,Manila, to be my lawful representative in the withdrawal of the
scrap/unserviceable rails awarded to me.
For this reason, I have given her the ORIGINAL COPY of the AWARD, dated May 5, 1980 and O.R. No. 8706855 dated May 20,
1980 which will indicate my waiver of rights, interests and participation in favor of LIZETTE R. WIJANCO.
1
contract should be read and interpreted together. It is clear from the foregoing of what Romualdezs intent
was.
Lizettes acts also confirmed the fact of agency (subseq. letters by Sps referring to themselves as agents,
withdrawal receipt) hence shes estopped
In the absence of statute, no form or method of execution is reqd for a valid power of atty