Prats v. Court of Appeals

Prats v. Court of Appeals G.R. No. L-39822, January 31, 1978, Fernandez, J.

 

Facts:

 

In 1968, Antonio Prats, under the name of “ Philippine Real Estate Exchange” instituted against Alfonso Doronilla and PNB a case to recover a sum of money and damages. Doronilla had for sometime tried to sell his 300 ha land and he had designated several agents for that purpose at one time. He offered the property to the Social Security System but was unable to consummate the sale. Subsequently he gave a written authority in writing to Prats to negotiate the sale of the property. Such authorization was published by Prats in the Manila Times. The parties agreed that Prats will be entitled to 10% commission and if he will be able to sell it over its price, the excess shall be credited to the latter plus his commission. Thereafter, Prats negotiated the land to the SSS. SSS invited Doronilla for a conference but the latter declined and instead instructed that the former should deal with Prats directly. Doronilla had received the full payment from SSS. When Prats demanded from him his professional fees as real estate broker, Doronilla refused to pay. Doronilla alleged that Prats had no right to demand the payment not rendered according to their agreement and that the authority extended to Prats had expired prior to the closing of the sale..

 

Issue: Whether petitioner was the efficient procuring cause in bringing about the sale of respondent’s land to the SSS.

 

Ruling:

 

The Supreme Court ruled that Prats was not the efficient procuring cause of the sale. It was not categorical that it was through Prats efforts that meeting with the SSS official to close the sale took place. The court concluded that the meeting took place independently because the SSS had manifested disinterest in Prats intervention. However, in equity, the court noted that Prats had diligently taken steps to bring back together Doronilla and SSS. Prats efforts somehow were instrumental in bringing them together again and finally consummating the sale although such finalization was after the expiration of Prats extended exclusive authority. Doronilla was ordered to pay Prats for his efforts and assistance in the transaction