GR L 4070; (January, 1908) (CRITIQUE)
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THE AI-ASSISTED CRITIQUE
The trial court’s reliance on the motion filed by Attorney Waite as evidence of revocation constitutes a clear error in applying the law of agency. A revocation of a power of attorney must be communicated to the agent to be effective, and the record contains no testimony from the defendant or Waite establishing the latter’s authority or any act of revocation. The court improperly inferred a revocation from a mere notice of motion, which itself lacked foundational evidence of being an authorized act of the principal. This reasoning violates the principle that an agency relationship continues until properly terminated, and it improperly shifts the burden by treating an unsubstantiated court filing as conclusive proof of a legal fact. The Supreme Court correctly identified this as a failure of proof, as the defendant presented no legal evidence to overcome the validly executed power of attorney.

The factual findings by the trial court were internally inconsistent, creating a flawed foundation for its legal conclusion. While the judge correctly found the power of attorney was duly executed—based on overwhelming, uncontradicted eyewitness testimony—he then disregarded the legal consequences of that finding by speculating about revocation without supporting evidence. This creates a logical disconnect: having validated the agency’s creation, the court then nullified it based on a document whose provenance and authority were never established. The decision, therefore, fails under Res Ipsa Loquitur reasoning; the existence of the unchallenged power of attorney and the admitted payments for services rendered should have dictated the outcome without resort to unsupported inferences about subsequent events.

The Supreme Court’s reversal properly enforces the doctrines of quantum meruit and contractual good faith. The defendant did not contest the reasonableness of the P2,000 payment for legal services, and the plaintiff-agent testified to keeping her informed of payments, which she initially accepted. By allowing recovery minus the admitted counterclaim, the high court ensures the lawyer receives compensation for services actually rendered under a then-operative authority, preventing unjust enrichment. The ruling underscores that a principal cannot silently acquiesce to an agent’s actions and later disavow liability for necessary expenses absent clear, communicated revocation—a fundamental safeguard in agency relationships that the trial court’s judgment would have undermined.