Facts:

• In 19965, Alimario who worked as brokers, offered to sell to the

petitioners, Sps. Litonjua, parcels of land. The petitioners and
respondent Fernandez, who is allegedly acting as agents of the
respondent-owners, agreed that the petitioners would buy the
property. Also, it was agreed that respondent Fernandez would
present a special power of attorney executed by the owners of the
property, authorizing her to sell the property for and in their behalf. 
Facts:
• Hoewever, respondent was told by her cousin that he was not
selling his share since there were already tenants on the said
lands. Hence, respondent Fernandez wrote the
petitioners informing them that they thereby changed their mind
and that the sale will no longer push through.
Issue:
• Whether or not there was a perfected contract of sale between
the parties?
Ruling
• No. 
• ART. 1878. Special powers of attorney are necessary in the following
cases:
    … (5) To enter into any contract by which the ownership of an immovable
is transmitted or acquired either gratuitously or for a valuable consideration;
Ruling:
• In this case, respondent Fernandez specifically denied that she was
authorized by the respondents-owners to sell the properties, both in her
answer to the complaint and when she testified and, no evidence on record
that the respondents-owners ratified all the actuations of respondent
Fernandez in connection with her dealings with the petitioners. 
• Hence, Any sale of real property by one purporting to be the agent of the
registered owner without any authority therefor in writing from the said
owner is null and void.