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The doctrine of estoppel is based upon the grounds of public policy, fair
dealing, good faith and justice, and its purpose is to forbid one to speak
against his own act, representations, or commitments to the injury of one
to whom they were directed and who reasonably relied thereon. The
doctrine of estoppel springs from equitable principles and the equities in
the case. It is designed to aid the law in administration of justice where
without its aid injustice might result. It has been applied by this Court
wherever and whenever special circumstances of a case so
demand. (Megan Sugar Corporation v. Regional Trial Court of Iloilo,
June 1, 2011)


The Court finds that the signature of Abcede is sufficient to bind PRHC.
As its construction manager, his very act of signing a letter embodying
the P 36 million escalation agreement produced legal effect, even if there
was a blank space for a higher officer of PHRC to indicate approval
thereof. Abcede had signed, on behalf of PRHC, other documents that
were almost identical to the questioned letter-agreement. It thereby
effectively admits that this individual had actual authority to sign on its
behalf with respect to these construction projects. (Philippine Realty and
Holding Corp. vs. Ley Const, June 13, 2011)

The relationship of agency is one where one party called the principal,
authorizes another, called the agent, to act for and in his behalf in
transactions with third persons. The essential elements of agency are: (1)
there is consent, express or implied of the parties to establish the
relationship; (2) the object is the execution of a juridical act in relation to
a third person; (3) the agent acts as a representative and not for himself,
and (4) the agent acts within the scope of his authority. Agency is
basically personal, representative, and derivative in nature. The authority
of the agent to act emanates from the powers granted to him by his
principal; his act is the act of the principal if done within the scope of
the authority. He who acts through another acts himself. (Sps. Fernando
and Lourdes Viloria vs. Continental Airlines, Inc. Jan 16, 2012)
Article 1891 of the Civil Code contains a few of the obligations owed by
an agent to his principal Every agent is bound to render an account of
his transactions and to deliver to the principal whatever he may have
received by virtue of the agency, even though it may not be owing to the
principal. Every stipulation exempting the agent from the obligation to
render an account shall be void. It is evident that the reason behind the
failure of petitioner to render an accounting to respondent is immaterial.
What is important is that the former fulfill her duty to render an account
of the relevant transactions she entered into as respondents agent.
(Caridad Segarra Sazon vs. Letecia Vasquez-Menancio. Februaru 22,
Every agent is bound to deliver to the principal whatever the former may
have received by virtue of the agency, even though that amount may not
be owed to the principal. (Caridad Segarra Sazon vs. Letecia Vasquez-
Menancio, February 22, 2012)
In agency, ratification is the adoption or confirmation by one person of an
act performed on his behalf by another without authority. The substance
of ratification is the confirmation after the act, amounting to a substitute
for a prior authority. Here, there was such a ratification by Marcos, as
borne out by his execution of the letter of acknowledgement on
September 12, 1996.As the tenor of the of acknowledgment indicated, he
was fully aware of the meaning and sense of every written word or
phrase, as well as of the legal effect of his confirmation thereby of his
agents act. It is axiomatic that a mans act, conduct and declaration,
wherever made, if voluntary, are admissible against him, for the reason
that it is fair to presume that they correspond with the truth, and it is his
fault if they do not. (Marcos V. Prieto vs. Court of Appeals, et al. June
18, 2012)