Manotok

Brothers vs. CA 5. On Jan 1969, the parties signed the deed of sale.
April 7 1993 | Campos, Jr. | Agency vs. Brokerage (sa outline) 6. Even though the sale is consummated, Saligumba never received any
commission (which should have been P20,554.5) due to refusal of petitioner.
Petitioners: Manotok Brothers, Inc 7. Saligumba claimed that it was because of his efforts that the Municipal Board
Respondents: CA, Salvado Saligumba passed the Ordinance.
8. Petitioner, on the other hand, does not recognize the Saligumba’s role as agent in
SUMMARY: Manotok Brothers, Inc. is the owner of a certain parcel of land and the transaction, on the following grounds:
building, which were formerly leased by Manila City and used by Claro M. Recto HS. a. Saligumba would be entitled to a commission only if the sale was
Petitioner authorized private respondent to negotiate with City of Manila for the sale consummated and the price paid within the period given where
of the property, with a promise to pay 5% as commission if sale is consummated. The Saligumba still has authority.
letters of authority were extended several times. Then, City of Manila passed an b. Saligumba was not the person responsible for the negotiation and
Ordinance, which appropriated the money needed to buy the property. Even though consummation. Petitioner alleged that it was Filomena Huelgas, the
the sale is consummated, Saligumba never received any commission. Saligumba PTA president of Claro M. Recto HS in 1967-68, who was responsible
claimed that it was because of his efforts that the Municipal Board passed the for the sale.
Ordinance. Petitioner, on the other hand, does not recognize the Saligumba’s role as 9. Saligumba testified the following:
agent in the transaction and alleged that since the Deed of Sale was signed after a. A meeting was set by Rufino Manotok at the office of the principal, with
Saligumba’s authority expired, he is not entitled to any commission. Issue in this case the then President of PTA (Atty. Bisbal), of the school to ask Saligumba
is whether Saligumba is entitled to the agreed commission fees. The Court rules in to negotiate the sale of the school lot and building to Manila City.
favor of Saligumba. Private respondent is the efficient procuring cause for without his b. Saligumba then went to Councilor Magsalin, the author of the
efforts, the municipality would not have anything to pass and the Mayor would not Ordinance, to present the project. He also went to Assessor’s Office for
have anything to approve. appraisal of the property’s value.
c. While these were happening, the letter of authority extended to
DOCTRINE: Saligumba expired.
• The agent is entitled to his commission when there is a close, proximate and d. After securing report from appraisal committee, he went to Mayor’s
causal connection between the agent’s efforts and labor and the principal’s sale office to indorse the matter
of his property. 10. Because of this, the sale was consummated. Manotok Inc received the full
• Revocation of agency does not prevent earning of sales commission where the payment of the purchase price but Saligumba was not able to receive a single
contract of sale had already been perfected and partly executed. centravo as commission.
11. Manotok Inc, on the other hand, testified that Filomeno Huelgas, the PTA

president in 1967, was the one who follow up the sale from the start with
FACTS:
Councilor Magsalin after it was approved.
1. Manotok Brothers, Inc. is the owner of a certain parcel of land and building,

which were formerly leased by Manila City and used by Claro M. Recto HS
PROCEDURAL:
2. Petitioner authorized respondent Saligumba to negotiate with the City of Manila
• RTC rendered judgment sentencing Manotok Inc. to pay private respondent
for the sale of the property for not less than P425,000. Petitioner also agreed to
(Saligumba) the commission fees.
pay respondent a 5% commission if sale is consummated.
• CA affirmed the ruling.
3. Petitioner, through its president Rufino Manotok, executed several letters, which

just extended the authority given to private respondent from July 1966 to May
ISSUE: Whether or not private respondent Saligumba is entitled to the five percent (5%)
14, 1968.
agent’s commission? YES
a. Last letter: gave authority to finalize and consummate the sale of

property for not less than P410,000. RATIO: Court ruled in favor of Saligumba (respondent)
4. Municipal Board of City of Manila passed an Ordinance, which appropriated the
sum of P410,816.00 for the purchase of property of Manotok Inc. 1. At first sight, it would seem that private respondent is not entitled to any
a. However, said ordinance was only signed by Mayor on May 17, 1968 – commission as he was NOT successful in consummating the sale between the
3 days after Saligumba’s authority expired.
 parties because the Deed of Sale was executed only after Saligumba’s
authority already expired.
2. However, going deeper into the case would reveal that the case is within the
coverage of the exception rather than of the general rule.
3. Based on Prats v. CA: The sale was only consummated after the expiration of
authority granted to the broker. In equity, the Court notes that petitioner had
diligently taken steps to bring back together the buyer and the seller. The
broker’s efforts somehow were instrumental in bringing the parties together.
4. Based from the foregoing, the private respondent should be paid with his
commission. Private respondent is the efficient procuring cause for without
his efforts, the municipality would not have anything to pass and the Mayor
would not have anything to approve.
5. When there is a close, proximate and causal connection between the
agent’s efforts and labor and the principal’s sale of his property, the agent
is entitled to a commission.
6. The City of Manila ultimately became the purchaser of petitioner’s property
mainly through the efforts of Saligumba.
a. It is to be noted that the ordinance was approved on April 26, 1968
while it was signed on May 17, 1968. 3 DAYS after the authority of
Saligumba expired.
7. Private respondent pursued with his goal of seeing that the parties reach an
agreement, on the belief that he alone was transacting the business with the City
Government as this was what petitioner made it to appear.
8. It is true that Filomeno Huelgas followed-up on the matter with Councilor
Magsalin BUT his intervention regarding the purchase came only AFTER the
ordinance had already been passed. Meaning, there was already meeting of the
minds between Manotok Inc and City of Manila due to Saligumba’s efforts.
9. Revocation of agency does not prevent earning of sales commission where
the contract of sale had already been perfected and partly executed.

WHEREFORE, the decision of CA is AFFIRMED.