[26] Manotok Brothers v.
CA ● Huelgas testified to the effect that after being inducted as PTA president in August,
G.R. No. 94753 | April 7, 1993 | J. Campos Jr.
SUMMARY: Salvador Saligumba, private respondent, was the agent for Manotok Brothers Inc.
He negotiated the sale for the property currently being leased by the City of Manila, used by
Claro M. Recto HS. However, Ordinance No. 6603, which appropriated the sum of P410,816 for
the purchase of the property which Saligumba was authorized to sell, was only passed and
signed after the expiration of Saligumba’s letter of authorization. Saligumba asked for his
commision, but petitioners denied it because he was no longer their agent when the sale was
consummated. RTC ruled in favor of Saligumba, CA affirmed RTC decision. Hence, the appeal
to the SC. SC held that Saligumba was still entitled to his commission, because the sale was
procured mainly through his efforts.
DOCTRINE: 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.
FACTS:
● The petitioner in this case is the owner of a parcel of land and building which was
leased to the City of Manila and was used by Claro M. Recto High School.
● Respondent Salvador Saligumba was the agent of the petitioner who negotiated with
the city for the sale of the said property.
○ Accordingly, he was given letters of authority that allowed him to negotiate
the property at a price not less than 425k.
○ He was to get a 5% commission from the said sale.
○ His authority was extended several times, the last one lasting for 180 days
from November 16, 1987, also it was at this time that petitioner allowed the
sale to be consummated for the amount of 410k.
● However, it was on April 26, 1968, when Ordinance No. 6603 passed, which
appropriated the sum of P410,816 for the purchase of the property which Saligumba
was authorized to sell.
○ Ordinance No. 6603 was SIGNED only on May 17, 1968, 183 days after the
last letter of authorization.
● Jan. 14, 1969 - parties signed the deed of sale of the subject property.
○ The initial 200k was already made.
○ April 8, 1969 - 2nd payment by a check in the amount of P210,816, which
fully satisfied the purchase price.
● Respondent Saligumba is now asking for his 5% commission, amounting to
P20,554.50.
● Manotok Brothers Inc. refuse to pay arguing that:
○ Saligumba would be entitled to a commission only if the sale was
consummated and the price paid within the period given in the respective
letters of authority.
○ Private respondent was not the person responsible for the negotiation and
consummation of the sale; instead it was Filomeno E. Huelgas, the PTA
president for 1967-68 of the Claro M. Recto HS.
● Manotok Bros. presented as its witnesses Filomeno Huelgas and Manotok Bros. Inc.
president, Rufino Manotok.
1967, he followed up the sale from the start with Councilor Magsalin until after it was
approved by the Mayor of Manila on May 17, 1968.
○ He also said that he came to know Rufino Manotok only in August 1968, at
which meeting the latter told him that he would be given a “gratification” in
the amount of P20,000 if the sale was expedited.
● Petitioner’s contention that as a broker, private respondent’s job is to bring together
the parties to a transaction.
● Accordingly, if the broker does not succeed in bringing the minds of the purchasor and
the vendor to an agreement with respect to the sale, he is not entitled to a
commission.
● RTC ruled in favor of Saligumba, CA affirmed RTC decision. Hence, the appeal to the
SC.
ISSUE w/ HELD & RATIO:
[1] W/N the private respondent is entitled to the 5% commission - YES (this question is important
because it will also answer if Saligumba is an agent, and therefore, is entitled to the commission)
● SC: [Prats v. CA] the Court ruled in favor of claimant-agent, despite the expiration of
his authority, when a sale was finally consummated.
○ Prats (claimant-agent) was NOT the efficient procuring cause in bringing
about the sale (prescinding from the fact of expiration of his exclusive
authority), STILL petitioner was awarded compensation for his services.
○ Under the circumstances, the Court grants in equity the sum of P100,000 by
way of compensation for his efforts and assistance in the transaction, which
however was finalized and consummated after the expiration of his
exclusive authority.
● It follows then that Saligumba, with more reason, should be paid his commission.
While in Prats vs. Court of Appeals, the agent was NOT even the efficient procuring
cause in bringing about the sale, unlike in the case at bar, it was still held therein that
the agent was entitled to compensation.
● In this case, Saligumba 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.
● [DOCTRINE] 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.
● Saligumba is the efficient procuring cause, because without his efforts, the
municipality would not have anything to pass and the Mayor would not have anything
to approve.
○ Also, the only party given a written authority by petitioner to negotiate the
sale from July 5, 1966 to May 1968 was Saligumba.
● SC agrees with Saligumba that the City of Manila ultimately became the purchaser of
petitioner’s property mainly through the efforts of Saligumba.
RULING: CA decision AFFIRMED. Manotok Brothers Inc. to pay P20,554.50 commission to
Saligumba.