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Agency; general power of attorney; an agency couched in general terms comprises only acts of

administration. The certification is a mere general power of attorney which comprises all of Joy
Training’s business. Article 1877 of the Civil Code clearly states that “[a]n agency couched in general
terms comprises only acts of administration, even if the principal should state that he withholds no
power or that the agent may execute such acts as he may consider appropriate, or even though the
agency should authorize a general and unlimited management.” Sally Yoshizaki v. Joy Training Center
of Aurora, Inc., G.R. No. 174978, July 31, 2013.