G.R. No. 1472
FACTS:
Plaintiffs-appellees E.J. Smith and Rafael Reyes, proprietors of the Philippine Gas Light Company, filed an action to recover the sum of 3,270 pesos (Mexican currency) from defendants-appellants Jacinta Lopez and Ignacia Lopez de Pineda. The amount represented the balance due for labor and materials used in installing a water system and sanitary fixtures in the defendants’ house, located at No. 142 Calle Dulumbayan. The contract for the work was entered into by one of the plaintiffs with Nicasio Lopez, the defendants’ father, who managed the property. No specific price was stipulated. The defendants denied liability, arguing, among other things, that Nicasio Lopez had no authority to contract on their behalf and that the plaintiffs lacked capacity to sue as a partnership. The trial court rendered judgment in favor of the plaintiffs. The defendants appealed.
ISSUE:
1. Whether the plaintiffs had the legal capacity to sue.
2. Whether Nicasio Lopez had the authority, express or implied, to bind the defendants to the contract.
3. What is the proper amount recoverable, considering the defendants owned only one-half of the property where the work was performed.
RULING:
1. On Capacity to Sue: The Supreme Court held that the plaintiffs, Smith and Reyes, were suing in their individual capacities as co-owners of the business, not as a formal partnership entity. They were therefore the real parties in interest and had the capacity to enforce their rights under the contract.
2. On Authority and Liability: The Court ruled that Nicasio Lopez acted as a voluntary agent for the defendants. Although no express power of attorney was shown, his authority was implied. The defendants, as owners, benefited from the necessary sanitary improvements done at the behest of the Board of Health and never objected to the work. Consequently, they were liable under the principles of quasi-contract and agency (Articles 1892 and 1893 of the Civil Code). Their father’s actions were deemed ratified.
3. On the Recoverable Amount: The Court found the reasonable value of the work to be 3,467.40 pesos (Mexican currency). After deducting a prior payment of 750 pesos, the balance was 2,717.40 pesos. However, the evidence established that the defendants owned only one-half of the house; the other half belonged to the heirs of Vicente Faustino Cruz, who were not made parties to the suit. Pursuant to procedural rules, the judgment could only affect the defendants’ interest. Therefore, the defendants were liable for only one-half of the balance, or 1,358.70 pesos (Mexican currency), plus legal interest from the filing of the complaint.
The appealed judgment was MODIFIED. The plaintiffs’ right to institute a separate action against the co-owners (heirs of Vicente F. Cruz) for the other half of the amount was reserved.
