G.R. No. 94753 . April 7, 1993.
MANOTOK BROTHERS, INC., petitioner, vs. THE HONORABLE COURT OF APPEALS, THE HONORABLE JUDGE OF THE REGIONAL TRIAL COURT OF MANILA (Branch VI), and SALVADOR SALIGUMBA, respondents.

FACTS

Petitioner Manotok Brothers, Inc. owned a parcel of land and building leased by the City of Manila for Claro M. Recto High School. Through a series of letters dated July 5, 1966, March 4, 1967, June 26, 1967, and finally November 16, 1967, petitioner authorized private respondent Salvador Saligumba to negotiate the sale of the property to the City of Manila for not less than P410,000.00, agreeing to pay him a 5% commission upon consummation and payment. The last letter extended his authority for 180 days, expiring on May 14, 1968. The Municipal Board of Manila passed Ordinance No. 6603 appropriating the purchase price on April 26, 1968, while Saligumba’s authority was still in force. The City Mayor signed the ordinance on May 17, 1968, three days after the authority expired. The deed of sale was signed on January 14, 1969, and full payment was made by April 8, 1969. Petitioner refused to pay Saligumba’s commission, claiming he was not the effective cause of the sale and that the sale was not consummated within the authorized period. Saligumba filed a complaint. The trial court ruled in his favor, ordering payment of the commission and attorney’s fees, a decision affirmed by the Court of Appeals. Petitioner’s initial appeal to the Supreme Court (G.R. No. 78898) was dismissed due to inability to locate private respondent for comment. Petitioner then filed this Petition for Relief.

ISSUE

Whether or not private respondent Salvador Saligumba is entitled to the five percent (5%) agent’s commission for the sale of the property to the City of Manila.

RULING

Yes, private respondent is entitled to the commission. The Supreme Court affirmed the decision of the Court of Appeals. The Court ruled that an agent is entitled to a commission when there is a close, proximate, and causal connection between the agent’s efforts and the principal’s sale of the property. The City of Manila ultimately became the purchaser mainly through Saligumba’s efforts. Although the Mayor signed the ordinance three days after Saligumba’s authority expired, the ordinance was approved by the Municipal Board on April 26, 1968, while his authority was still in force. Furthermore, Saligumba was the only party given written authority by petitioner to negotiate the sale from July 5, 1966, to May 14, 1968. The intervention of another individual, Filomeno Huelgas, occurred only after the ordinance had been passed, meaning the buyer had already agreed to the purchase. Saligumba’s labor set in motion the chain of events that produced the sale. The temporary restraining order issued earlier was lifted.