G.R. No. 192085; February 22, 2012
CARIDAD SEGARRA SAZON, Petitioner, vs. LETECIA VASQUEZ-MENANCIO, represented by Attorney-in-Fact EDGAR S. SEGARRA, Respondent.

FACTS

Respondent Leticia Vasquez-Menancio, a US resident, entrusted the management of her nine parcels of land in Albay to petitioner Caridad S. Sazon in 1979. The properties included residential lots, ricelands, and coconut lands. Respondent alleged that petitioner, as administrator, collected all fruits and income from the productive properties but failed to render a full accounting and remit the proceeds, instead appropriating them for personal use. In 1997, respondent revoked petitioner’s authority and demanded accounting, turnover of possession, and remittance of income, but petitioner refused.
Petitioner denied the allegations, claiming some properties were non-income producing and that expenses consumed any income. She presented five letters sent to respondent as proof of accounting and asserted she never received demands for accounting. She also claimed partial ownership or possession of some lots by her mother. The Regional Trial Court (RTC) initially ruled for respondent but reversed upon petitioner’s motion for reconsideration. The Court of Appeals (CA) reinstated the first RTC decision with modification, ordering petitioner to pay ₱908,112.62 for unremitted income from 1979-1997, net of expenses and compensation.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s decision holding petitioner liable to account for and remit the fruits and income from the subject properties.

RULING

The Supreme Court denied the petition and affirmed the CA decision with modification, remanding for precise recomputation. The legal relationship was a contract of agency, where an agent is obligated to render an account of her administration. Petitioner, as agent, failed to substantiate her claim of regular accounting. The five letters she presented were insufficient as they were unilateral, lacked detailed financial data, and did not prove respondent’s receipt or acknowledgment. Petitioner’s bare denials and unsubstantiated claims of non-productivity and offsetting expenses could not overcome her duty to account.
The Court upheld the finding of an implied renewal of the agency, as petitioner continued administering the properties after the original agreement. However, it found the CA’s computation of net income (₱908,112.62) based solely on tax declarations and general price data from government agencies to be insufficiently precise. The Court thus ordered a remand to the RTC for a more exact determination, directing the parties to submit evidence on actual harvests, expenses, and prevailing prices from 1979-1997 to compute the exact amount due, after deducting proven expenses and petitioner’s compensation. The agent’s duty to account is strict, and her failure to keep proper records justified the order for accounting and remittance.