Soriamont Steamship Agencies Inc.

& Ronas v Sprint Transport Services, & Papa

Sprint filed for a complaint for a sum of money against Soriamont and Ronas
Subject of dispute: ELA (EQUIPMENT LEASE AGREEMENT)

Sprint alleges:

It entered into a lease agreement for Equipment with Soriamont

Sprint agreed to lease chassis units for the transport of container vans

Thru authorization letters, Ronas (on behalf of Soriamont and PAPA

TRUCKING SERVICES [PTS]) were able to withdraw 2 chassis units from the

container yard of Sprint.

Soriamont and Ronas failed to pay rental fees.
Sprint was subsequently informed that the equipment was LOST
Despite demands, Soriamont and Ronas failed to pay rental fees and failed to
replace equipment.

Soriamont and Ronas alleges:

It was [PTS] who withdrew the equipment.

Soriamont and Ronas filed a Third Party Complaint against [PTS], who failed to
answer and thus was declared in default

RTC

favored Sprint, held Soriamont liable

CA
-

found that the contract contained an AUTOMATIC RENEWAL CLAUSE

Found that Soriamont authorized the withdrawal of [PTS] of the equipment
Affirmed RTC decision

ISSUE: Whether or not PTS is an agent of Soriamont?

Soriamont is essentially challenging court findings that PTS withdrew the

equipment as an agent of Soriamont.

In effect, Soriamont is raising questions of fact which is NOT ALLOWED
Rule 45 -> only questions of law may be raised in a petition for review

Evidence shows that the preponderance of evidence supports the existence of an

agency relationship between Soriamont and PTS.

The ELA explicitly authorized Soriamont to appoint a representative who shall

withdraw and return the leased chassis units (which is PTS)
Since the ELA was not shown to be terminated, its AUTOMATIC RENEWAL
CLAUSE took effect pursuant to their contract.
The settled rule is that persons dealing with an assumed agent are bound at
their peril; and if they would hold the principal liable, they must ascertain not only
the fact of agency, but also the nature and extent of authority, and in case either is
controverted, the burden of proof is upon them to prove it. Sprint has successfully
discharged this burden.
Alternatively, if PTS is found to be its agent, Soriamont argues that PTS is liable
for the loss of the subject equipment, since PTS acted beyond its authority as
agent. Soriamont cites Article 1897 of the Civil Code, which provides:
Art. 1897. The agent who acts as such is not personally liable to
the party with whom he contracts, unless he expressly binds himself or
exceeds the limits of his authority without giving such party sufficient
notice of his powers.

The burden falls upon Soriamont to prove its affirmative allegation that PTS
acted in any manner in excess of its authority as agent, thus, resulting in the loss of
the subject equipment. To recall, the subject equipment was withdrawn and used by
PTS with the authority of Soriamont. And for PTS to be personally liable, as agent, it is
vital that Soriamont be able to prove that PTS damaged or lost the said equipment
because it acted contrary to or in excess of the authority granted to it by
Soriamont. As the Court of Appeals and the RTC found, however, Soriamont did not
adduce any evidence at all to prove said allegation.