GR 2962; (February, 1907) (Digest)
FACTS:
B.H. Macke and W.H. Chandler, doing business as Macke, Chandler & Co., sold goods worth ₱351.50 to José Camps, who operated the “Washington Café.” The goods were delivered in February‑March 1905; Camps paid only ₱174, leaving a balance of ₱177.50. The sellers demanded payment, but Camps, through Ricardo Flores, who claimed to be the defendant’s agent, refused, stating the principal was “away in the provinces.” Flores acknowledged receipt of the goods and the partial payment. The plaintiffs proved a written sub‑lease dated May 25 1904 whereby Galmes, former owner of the café, sublet the premises to Camps. The contract bears Camps’ signature as “sublessee” and the notation “managing agent” beside Flores’s signature. Galmes testified to the existence of the contract and inventory, but could not determine whether Flores acted as agent or sublessee. Camps did not testify and presented no evidence.
ISSUE:
Whether José Camps, as principal, is bound by the purchases made by Ricardo Flores, i.e., whether Flores acted as an authorized (actual or apparent) managing agent capable of obligating the principal for the goods supplied.
RULING:
The Supreme Court held that the evidence established Flores as Camps’s managing agent with authority to procure supplies necessary for the operation of the café. The contract and inventory expressly label Flores “managing agent,” and his presence in charge of the business during the principal’s absence demonstrated actual authority. Under Section 333, subsection 1 of Act No. 190, a principal who represents another as his agent cannot later repudiate that agency to the prejudice of innocent third parties. Absent proof to the contrary, the law presumes an agent’s authority includes the usual acts required to fulfill the agency, such as ordering reasonable quantities of goods for a hotel bar. Consequently, the plaintiff’s claim for the unpaid balance is valid, and the trial court’s judgment in favor of Macke and Chandler is affirmed, with costs awarded against the appellant. The decision underscores the principle that a principal is estopped from denying the authority of a person he has held out as his agent, thereby protecting parties dealing in good faith with apparent agents.
