[11] FILIPINAS LIFE ASSURANCE CO. v.
PEDROSO RELEVANT PROVISION(S)
G.R. No. 159489; February 04, 2008; Quisumbing, J.
FACTS
TOPIC: Teresita Pedroso is a policyholder of a 20-year endowment life insurance
issued by Filipinas Life Assurance Co.
SUMMARY o Pedroso claims Renato Valle was her insurance agent since 1972
Pedroso is a policyholder of a 20-year endowment life insurance issued by and Valle collected her monthly premiums.
petitioner Filipinas Life Assurance Company. On the first week of January 1977, Valle o In the first week of January 1977, Valle told her that the Filipinas
(her insurance agent since 1972) told her that the Filipinas Life Escolta Office was Life Escolta Office was holding a promotional investment program
holding a promotional investment program. Enticed, she initially invested and issued a for policyholders.
post-dated check dated January 7, 1977 for P10,000. In return, Valle issued Pedroso o It was offering 8% prepaid interest a month for certain amounts
his personal check. She called the Escolta office and talked to Alcantara, the deposited on a monthly basis. Enticed, she initially invested and
administrative assistant, who referred her to the branch manager, Apetrior. Pedroso issued a post-dated check for P10,000.
inquired about the promotional investment and Apetrior confirmed that there was such o In return, Valle issued Pedroso his personal check for P800 for the
a promotion. From the records, the check, with the endorsement of Alcantara at the 8% prepaid interest and a Filipinas Life Agent receipt.
back, was deposited in the account of Filipinas Life. Pedroso waited for the maturity of Pedroso called the Escolta office and talked to Francisco Alcantara, the
her initial investment. administrative assistant, who referred her to the branch manager, Angel
To collect the amount, Pedroso personally went to the Escolta branch where Apetrior.
Alcantara gave her the P10,000 in cash. After a second investment, she made 7 to 8 o Pedroso inquired about the promotional investment and Apetrior
more investments in varying amounts. Upon maturity of the subsequent investments, confirmed that there was such a promotion. She was even told she
Valle would take back from Pedroso the corresponding yellow-colored agent's receipt could push through with the check she issued.
he issued to the latter. Pedroso told respondent Palacio, also a Filipinas Life insurance o From the records, the check, with the endorsement of Alcantara at
policyholder, about the investment plan and also made an investment. the back, was deposited in the account of Filipinas Life with the
However, when Pedroso tried to withdraw her investment, Valle did not want Commercial Bank and Trust Company, Escolta Branch.
to return some P17,000 worth of it. Palacio. Hence, respondents filed an action for the Relying on the representations made by Filipinas Life’s duly authorized
recovery of a sum of money. RTC: held Filipinas Life and its co-defendants Valle, representatives Apetrior and Alcantara, as well as having known agent Valle
Apetrior and Alcantara jointly and solidarily liable to the respondents. CA: affirmed the for quite some time, Pedroso waited for the maturity of her initial investment.
trial court's ruling. o A month after, her investment of P10,000 was returned to her after
she made a written request for its refund.
DOCTRINE o To collect the amount, Pedroso personally went to the Escolta
Qui per alium facit per seipsum facere videtur. branch where Alcantara gave her the P10,000 in cash.
o “He who does a thing by an agent is considered as doing it himself.” o After a second investment, she made 7 to 8 more investments in
o The act of the agent is considered that of the principal itself. varying amounts, totaling P37,000 but at a lower rate of 5% prepaid
GENERAL RULE: the principal is responsible for the acts of its agent done interest a month. Upon maturity of Pedroso’s subsequent
within the scope of its authority, and should bear the damage caused to third investments, Valle would take back from Pedroso the
persons. corresponding agent’s receipt he issued to the latter.
o When the agent exceeds his authority, the agent becomes Pedroso told respondent Jennifer Palacio, also a Filipinas Life insurance
personally liable for the damage. policyholder, about the investment plan. Palacio made a total investment of
o But even when the agent exceeds his authority, the principal is still P49,550 but at only 5% prepaid interest.
solidarily liable together with the agent if the principal allowed the o However, when Pedroso tried to withdraw her investment, Valle did
agent to act as though the agent had full powers. The acts of an not want to return some P17,000 worth of it. Palacio also tried to
agent beyond the scope of his authority do not bind the principal, withdraw hers, but Filipinas Life, despite demands, refused to
unless the principal ratifies them, expressly or impliedly. return her money.
ISSUE(S)/HELD Filipinas Life had clothed Valle with apparent authority; hence, it is now
WON Filipinas Life is jointly and severally liable with Apetrior and Alcantara on estopped to deny said authority.
the claim of Pedroso and Palacio (or WON its agent Renato Valle is solely liable Innocent third persons should not be prejudiced if the principal failed to adopt
to Pedroso and Palacio). – YES the needed measures to prevent misrepresentation, much more so if the
Pedroso and Palacio had invested P47,000 and P49,550, respectively. These principal ratified his agent’s acts beyond the latter’s authority.
were received by Valle and remitted to Filipinas Life, using Filipinas Life’s
official receipts. DISPOSITIVE: WHEREFORE, the petition is DENIED for lack of merit.
o Valle’s authority to solicit and receive investments was also
established by the parties. When Pedroso and Palacio sought
confirmation, Alcantara, holding a supervisory position, and
Apetrior, the branch manager, confirmed that Valle had authority.
o While it is true that a person dealing with an agent is put upon
inquiry and must discover at his own peril the agent’s authority, in
this case, Pedroso and Palacio did exercise due diligence in
removing all doubts and in confirming the validity of the
representations made by Valle.
Filipinas Life, as the principal, is liable for obligations contracted by its agent
Valle. By the contract of agency, a person binds himself to render some
service or to do something in representation or on behalf of another, with the
consent or authority of the latter.
[see doctrine]
o The general rule is that the principal is responsible for the acts of
its agent done within the scope of its authority, and should bear the
damage caused to third persons.
o When the agent exceeds his authority, the agent becomes
personally liable for the damage. But even when the agent exceeds
his authority, the principal is still solidarily liable together with the
agent if the principal allowed the agent to act as though the agent
had full powers.
o The acts of an agent beyond the scope of his authority do not bind
the principal, unless the principal ratifies them, expressly or
impliedly.
Ratification – adoption or confirmation by one person of an act performed on
his behalf by another without authority
Even if Valle’s representations were beyond his authority as a debit/insurance
agent, Filipinas Life, through Alcantara and Apetrior expressly and knowingly
ratified Valle’s acts.
o Filipinas Life benefited from the investments deposited by Valle in
the account of Filipinas Life.
RULING
Filipinas Life cannot profess ignorance of Valle’s acts. Even if Valle’s
representations were beyond his authority as a debit/insurance agent,
Filipinas Life thru Alcantara and Apetrior expressly and knowingly ratified
Valle’s acts.
It cannot even be denied that Filipinas Life benefited from the investments
deposited by Valle in the account of Filipinas Life. In our considered view,
