G.R. No. L‑2589
October 24, 1906

FACTS
Mariano Devesa (plaintiff) sued Alejandro Montelibano (defendant) to recover possession of a parcel of land that Devesa claimed to own. Montelibano contended that he had purchased the land from Devesa through Devesa’s authorized agent, José F. Martínez. The dispute turned on whether Martínez was lawfully empowered by Devesa to sell the subject real estate.

Devesa produced two documents (Exhibits A and I).

Exhibit A (June 13 1902) is a letter granting attorney D. Antonio Herrero a “broad power” to act for Devesa in all judicial and extrajudicial matters throughout the Philippine Archipelago. The authority was later transferred to Martínez on June 20 1902.

Exhibit I (August 30 1902) is a letter from Devesa to Martínez requesting various services, notably the “gestion de la venta de la hacienda Manapla.” The hacienda mentioned is not the parcel in controversy.

Martínez testified that his authority derived solely from these exhibits. The court found that neither document expressly authorized him to sell the specific land at issue, and the deed he executed as attorney‑in‑fact did not convey title away from Devesa.

ISSUE
Whether José F. Martínez, acting as attorney‑in‑fact for Mariano Devesa, possessed valid authority to sell the subject real property, thereby vesting title in Alejandro Montelibano.

RULING
The Supreme Court affirmed the judgment of the lower court. It held that:

1. The letters granted Martínez a general agency for legal and administrative matters but did not confer authority to sell the land in dispute.
2. Consequently, the deed executed by Martínez did not divest Devesa of ownership.
3. The plaintiff’s title remained intact; the defendant’s claim of purchase was unsupported.

The decision affirmed the lower court’s judgment, ordered costs against the appellant, and set the case for remand to the trial court after twenty days for entry of judgment and ten days thereafter for proper further action.