Modes of Extinguishment of Agency  Estoppel of third persons – a third person, having dealt with one as

1. Revocation; coupled with an interest
Art. 1873. If a person specially informs another or states by public
advertisement that he has given a power of attorney to a third person,
the latter thereby becomes a duly authorized agent, in the former case
with respect to the person who received the special information, and
in the latter case with regard to any person.
The power shall continue to be in full force until the notice is rescinded
in the same manner in which it was given. (n)
an agent may be estopped to deny the agency as against the
principal, agent, or third persons in interest.
o He will not, however, be estopped where he has withdrawn
from the contract made with the unauthorized agent before
receiving any benefits thereunder.
 Estoppel of the government – the government is neither estopped
by the mistake or error on the part of its agents.
o But it may be estopped through affirmative acts of its officers
acting within the scope of their authority.

Two ways of communication of existence of agency: Agency by estoppel vs implied agency

1. By special information – the person appointed as agent is
considered such with respect to the person to whom it was given Agency by estoppel Implied agency
2. By public advertisement – the agent is considered as such with There is no agency at
regard to any person. all, but the one
o Public advertisement may be made in any form. assuming to act as There is an actual
In either case, the agency is deemed to exist whether there is actually an agent has apparent or agency.
agency or not. ostensible, although
not real authority to The principal alone is
The power of attorney must be revoked in the same manner in which it represent another. liable.
was given.
It is not a real agency.
 If the agency has been entrusted for the purpose of contracting with Existence of actual
Estoppel caused by
specified persons, its revocation shall not prejudice the latter if they agency
principal – principal is
were not given notice thereof (Art. 1921).
liable to any third
o Public advertisement is not sufficient unless the third person person who relied on
has actual knowledge of the revocation. the
 If the agent had general powers, revocation does not prejudice third misrepresentation.
persons who acted in good faith and without knowledge of the
revocation. Estoppel caused by
o Notice of revocation in a newspaper of general circulation is a the agent – only the
sufficient warning to third persons (Art. 1922) agent is liable.
 Revocation made in any manner is effective where the person Can be invoked only
dealing with the agent has actual knowledge thereof. by a third person who
Reliance is not
o Otherwise, bad faith and fraud would be committed. in good faith relied on
necessary since the
Reliance by third the conduct of the
agent is a real agent.
persons principal in holding
Estoppel to deny agency
the agent out as being
 Estoppel of agent – one professing to act as an agent for another authorized.
may be estopped to deny his agency both as against his asserted The principal is equally liable.
principal and the third persons interest in the transaction in which The apparent agent is
he engaged. not agent at all and as
 Estoppel of principal against the principal,
has none of the rights
One who knows that another is acting as of an agent.
his agent and fails to repudiate his acts,  Except where the
As to agent or accepts the benefits of them, will be principal’s
The agent is a real
estopped to deny the agency as against conduct or
agent with all the
such other. representations
rights and liabilities.
To estop the principal from denying his are such that the
liability to a third person, he must have agent reasonable
known or be charged with knowledge of believed that the
As to sub-agent principal intended
the fact of the transaction and the terms Nature of authority
of the agreement between the agent and him to act as an
sub-agent. agent in the
One who knows that another is acting as matter.
his agent or permitted another to appear Restricted to cases in
as his agent, to the injury of third persons which the authority is
Being an actual
As to third persons who have dealt with the apparent agent not real but apparent.
agency, it is a fact to
as such in good faith and in the exercise If the estoppel is on
be proved by
of reasonable prudence is estopped to the ground of
deductions or
deny the agency. negligence or fraud on
inferences from
the part of the
other facts.
principal, the agency is
allowed upon the
 theory that when one
of two innocent
persons must suffer
the loss, the loss
should fall upon him
whose conduct
brought about the
situation.
Art. 1919. Agency is extinguished:
(1) By its revocation;
(2) By the withdrawal of the agent;
(3) By the death, civil interdiction, insanity or insolvency of the
principal or of the agent;
(4) By the dissolution of the firm or corporation which entrusted or
accepted the agency;
(5) By the accomplishment of the object or purpose of the agency;
(6) By the expiration of the period for which the agency was
constituted. (1732a)
When once shown to have existed, an agency relation will be presumed
to have continued, in the absence of anything to show its termination.
 The burden of proving a revocation or other termination of an
agency is on the party asserting it.
Modes of extinguishment of agency
1. By agreement (Nos. 5 and 6)
2. By the subsequent acts of the parties which may be either:
o By the act of both parties or by mutual consent; or
o By the unilateral act of one of them
3. By operation of law
Since agency requires the presence, capacity, and solvency of both the
principal and agent, the death, civil interdiction, insanity, or insolvency of
either party terminates the agency.
 This is true notwithstanding that the agency period has not yet
expired.
Whether the death of one of two or more principals or of one of two or
more agents terminates the agency depends upon the intention of the
parties.
 Generally, the death of one of several principals does not revoke the
agent’s authority nor does the death of one of several agents put an
end to the agency of all, whether the responsibility of the several
principals or agents is joint or solidary.
 The intention of the parties controls except as otherwise provided
by law.
Civil interdiction deprives the offender during the period of his sentence
of the right to manage his property and dispose of such property by any
act or any conveyance inter vivos.
 A person under civil interdiction cannot validly give consent.
As by an act of insolvency the principal loses control of the subject matter
of the agency, the authority of the agent to act for his principal generally
ceases by operation of law upon an adjudication of the principal’s
insolvency.
 The insolvency of the agent will also ordinarily put an end to the
agency, at least if it is in any way connected with the agent’s
business which has caused his failure.
 But the insolvency of the agent will not destroy any right he may
have under a power coupled with interest.
General rule on the death of the principal or agent: by reason of the very
nature of the relationship between the principal and agent, agency is
extinguished ipso jure upon the death of either principal or agent.
 Although a revocation of a power of attorney to be effective must
be communicated by the parties concerned, yet a revocation by
operation of law, such as by death of the principal, is, as a rule,
instantaneously effective inasmuch as “by legal fiction the agent’s
exercise of authority is regarded as an execution of the principal’s
continuing will.”
 On the other hand, if the agent dies, he can no longer act for the
benefit and representation of the principal. There can be no
principal where there is no agent.
Exceptions:
1. The agency is coupled with an interest (Art. 1930)
2. The act of the agent was executed without knowledge of the death
of the principal and the third person who contracted with the agent
acted in good faith (Art. 1931)
The power of sale in a deed of mortgage is not revoked by the death of
the principal (mortgagor) as it is not an ordinary agency that contemplates
exclusively the representation of the principal by the agent but is primarily
an authority conferred upon the mortgagee for the latter’s own
protection.
 It is an ancillary stipulation supported by the same cause or
consideration for the mortgage and forms an essential and
inseparable part of that bilateral agreement. That power survives
the death of the mortgagor.
 The right exists independently of said stipulation and is clearly
recognized in Rule 86, Sec. 7 which grants to a mortgagee three
remedies that can be alternatively pursued in case the mortgagor
dies:
1. To waive the mortgage and claim the entire debt from the
estate of the mortgagor as an ordinary action
2. To foreclose the mortgage judicially and prove any deficiency
as an ordinary claim
3. To rely on the mortgage exclusively, foreclosing the same at
any time before it is barred by prescription without right to
file a claim for any deficiency.
Dissolution of a firm or corporation which entrusted (as principal) or
accepted (as agent) the agency, extinguished its juridical existence as far
as the right to go on doing ordinary business is concerned.
 Except for the purpose of winding up its affairs.
o After winding up, the existence of the firm or corporation is
terminated for all purposes.
 It is equivalent to its death.
At least as between the principal and agent, the fulfilment of the purpose
for which the agency is created ipso facto terminates the agency, even
though expressed to be irrevocable.
 It is illogical to assume the continued existence of authority to
do something which can no longer be done.
 An agency relationship may also be terminated by the non-
accomplishment of the object or purpose within a reasonable
time.
Where an agency, by the terms of the original agreement, is created for a
fixed period or is to end at a certain time, the expiration of such period or
the arrival of that time results in the termination of the relationship, even
though the purpose for which the agency was created has not been
accomplished.
  The parties may consent to the continuation of the agency
relationship beyond the period originally fixed.
 If no time is specified, it terminates at the end of a reasonable
period of time.
o The relationship is an agency at will and either party can
terminate the relationship at will by giving notice to the other.
 The period may be implied from the terms of the agreement, the
purpose of the agency, and the circumstances of the parties.
o Where the agent was appointed to manage the business
affairs while the principal is abroad, the agency automatically
terminates when the principal returns.
The list of modes provided by Art. 1919 is not exclusive.
 An agency may also be extinguished by the modes of
extinguishment of obligations in general when applicable.
o It is a basic rule of contract law that the parties can rescind or
cancel their contract by mutual agreement. It makes no
difference that the principal and agent originally agreed that
the agency was irrevocable.
 During the existence of a state of war, a contract of agency is
inoperative if the agent or the principal is an enemy alien.
o Since war suspends all commercial intercourse between
residents of two belligerent states, the general rule is that the
agency is terminated, as a matter of law, upon outbreak of
war.
 Legal impossibility
 Termination of the agent’s authority (loss of trust)
 Occurrence of a specified event – if the principal and agent have
originally agreed that the agency, or some particular aspect of it, will
continue until a specified event occurs, the happening of the event
terminates the agency (resolutory condition).
The loss or destruction of the subject matter of the agency or the
termination of the principal’s interest therein terminates the agent’s
authority to deal with reference to it.
Exceptions:
 An agreement to the contrary.
 If it is possible to substitute other material for that which was
destroyed without substantial detriment to either party or if the
destroyed subject matter was not essential to the contract.
 A partial loss or destruction of the subject matter.
o The contract of one engaged to as agent to secure freight for
the principal’s three boats cannot be cancelled merely
because one boat was destroyed.
The termination does not necessarily free the principal from liability.
 If the principal sells personal property in reference to the sale of
which he has appointed an agent, the agency is terminated but the
principal is liable in damages for his wrongful terminating act.
 Should the subject matter be destroyed without the fault of the
principal, no liability is assumed by him.
o But if a third party has given money or a thing of value for the
subject matter, he may sue the principal to recover the same.
Where there is a basic change in the circumstances surrounding the
transaction, which was not contemplated by the parties and which would
reasonably lead the agent to believe that the principal would not desire
him to act, the general rule is that the authority of the agent is terminated.
 Among those changes are changes in value of the subject matter
and changes in the general business climate which should indicate
to him that the principal would not desire him to act.
 The agent is under a duty to exercise due care in ascertaining the
business conditions in the market in which he is to act.
Exceptions:
 If the original circumstances are restored within a reasonable period
of time, the agent’s authority may be revived.
 Where the agent has reasonable doubts as to whether the principal
would desire him to act, his authority will not be terminated if he
acts reasonably.
o When in doubt, the agent can always protect himself by
contacting the principal for instructions if it is at all possible.
 Where the principal and agent are in close daily contact, the agent’s
authority to act will not terminate upon a change of circumstances
if the agent knows the principal is aware of the change and does not
give him new instructions.
While the relation of principal and agent is confidential, not all knowledge
acquired by the agent is of a confidential nature. Some are of so general
a nature that equity ought to attempt to restrict its subsequent use. The
court must determine:
1. Whether the knowledge or information, the use of which the
complainant seeks to enjoin, is confidential.
2. Whether, if it be confidential, in whole or in part, its use ought to be
prevented.
There is always the question whether encouragement of individual
initiative and competition should outweigh whatever unfairness seems to
be involved in the use of the information.
 Authorities generally agree that an employee lawfully entering
upon a competing business may be enjoined from the use of trade
secrets or processes, knowledge of the employer’s business
surreptitiously obtained, or copied lists of customers or information
about them.
 If information be imparted privately, the character of the secret is
immaterial, if it is one important to the business of the employer
and one to which them employment relates.
o For an employee to quit the employment and then use in the
service of a rival information of a confidential nature gained
in the prior employment, is contrary to good faith and fair
dealing.
 If one is employed to devise or perfect an instrument, or a means
for accomplishing a prescribed result, he cannot, after successfully
accomplishing the work for which he was employed, plead title
thereto as against his employer.
o That which he has been employed and paid to accomplish
becomes the property of his employer.
 An employee who learns in the course of or by reason of his
employment that the premises where his employer’s business is
conducted are of peculiar value to his employer has no right without
his employer’s knowledge to take a lease of those premises and hold
them as his own to the injury of his employer’s property.
The real principle upon which the agent is restrained from making use of
confidential information which he has gained in the employment of the
principal is that there is in the contract of service an implied contract on
the part of the agent that he will not, after the service is terminated, use
information which he has gained while the service has been subsisting to
the detriment of his former employer.
Art. 1920. The principal may revoke the agency at will, and compel the
agent to return the document evidencing the agency. Such revocation
may be express or implied. (1733a)
An agency may be terminated by the subsequent acts of the parties.
 When done by the principal, it is called “revocation.”
 When done by the agent, it is called “withdrawal.”
Wrongful termination can subject the terminating party to a suit for
damages.
An agency is generally revocable at will by the principal, subject only to has been terminated or is suspended, there is
the exceptions provided in Art. 1927. sufficient notice.
 This is true even though there was an agreement previous to the A revocation without notice to the agent will not
revocation that the agency should continue longer. render invalid an act done in pursuance of the
 Even a statement in the agreement that the agency cannot be authority.
terminated cannot affect the principal’s ability or power to Actual notice must be brought home to former
customers while notice by publication is sufficient
terminate it.
as to other persons.
o This is an exception to the rule that the validity or compliance
The general rule is that the acts of an agent within
of a contract cannot be left to the will of one of the parties.
the apparent scope of his authority are binding on
 This applies to both onerous or gratuitous agency. the principal as regards one who had formerly
The mere fact that the agency is to be irrevocable will not make it so; and dealt with him through the agent and who has no
the principal may still revoke the relationship at will. notice of the revocation, because such a person is
 Confidence, being the cardinal basis od the relation, it stands to justified in assuming the continuance of the agency
reason that it should cease when such confidence disappears. relationship.
o If this were not so, the contract would become unnatural, In the absence of any notice of revocation, the
converting the representation into a real alienation of principal may also be held liable even to third
personality something repugnant to the principles of modern persons who never dealt with the agent previous
law. to the revocation, if they, in common with the
To third persons public at large, are justified in believing that such
 The relationship is consensual and personal in nature and no one
agency continues to exist.
can be forced to retain another as his agent against his will.
It is not always necessary that the notice of
o But a principal may not revoke an agent’s authority for acts of
revocation be shown in a written oral
transactions the agent has already performed or entered into. communication from the principal or agent.

While the principal may have the absolute power to revoke, he must Whether a third person has received such notice
respond in damages for breach of contract where the termination is depends upon the facts of the particular case.
wrongful.
 It should be emphasized the revocation is a power and not a right. One may be deemed to have knowledge or notice
 The principal is liable for damages occasioned by the wrongful of the termination when he knows that the
discharge of the agent before the expiration of the period fixed. principal has ceased to do business, or is dealing
o The action for indemnity is not derived from law but from the with the subject matter of the agency, or the
contract of the parties. principal has appointed another agent of the
purpose.
 But where no time for the continuance of the agency has been fixed,
the principal is at liberty to terminate it at will subject only to the
The agent has the power to renounce the agency relationship subject only
requirements of good faith.
to the contractual obligations owing to the principal by giving notice to
o The principal is liable under Art. 19 when such termination
the principal that he will no longer serve as an agent.
would deprive the agent of his legitimate business. He must
 In effect, the agent resigns.
give the agent at least sufficient notice to allow the agent to
 If there is no contract existing between the parties or if the contract
recoup his expenses and, in some cases, to make a normal
is for no fixed or definite period of time, it is terminable by the agent
profit.
at will
o But an agent cannot legally terminate an agency in order to
If the authority of the agent is in writing, the principal can compel the
take advantage of the principal’s condition or to profit by
agent to return the document evidencing the agency.
information resulting from his agency.
 The purpose is to prevent the agent from making use of the power
 A statement in a contract that the authority cannot be terminated
of attorney and thus avoid liability to third persons who may
by either party for a specified time adds nothing to the contract; it
subsequently deal with the agent on the faith of the instrument.
is effective only to create liability for breach thereof.
 The law will not compel the parties to continue an agency if they do
Kinds of revocation
not want to do so since agency is a voluntary relationship. It deals
1. Express
with personal services, and, therefore, specific performance is
2. Implied
inappropriate.
o When the principal appoints a new agent for the same
It is not always necessary for the agent to renounce the agency expressly,
business or transaction or when the principal directly
as for example, where he has conducted himself in a manner clearly
manages the business entrusted to the agent (Aer. 1924)
incompatible with his duties as agent.
o The agent’s authority may also be revoked impliedly in the
same manner as in the case of appointment of an agent (Art.  When an agent abandons the object of his agency and acts for
1869) himself in committing a fraud upon his principal, his capacity as
agent ceases.
Notice of revocation  But the mere fact that the agent violates his instructions does not
amount to renunciation, and although he may thus render himself
Express notice to the agent that the agency is liable to the principal, he does not cease to be an agent.
revoked is not always necessary.
To agent
If the party to be notified actually knows, or has
reason to know, facts indicating that his authority
 Art. 1921. If the agency has been entrusted for the purpose of
contracting with specified persons, its revocation shall not prejudice
the latter if they were not given notice thereof. (1734)
Art. 1922. If the agent had general powers, revocation of the agency
does not prejudice third persons who acted in good faith and without
knowledge of the revocation. Notice of the revocation in a newspaper
of general circulation is a sufficient warning to third persons. (n)
Effect of revocation in relation to third persons
Its revocation will not prejudice such third
persons until notice thereof is given them
Notice is not required if the third person
already knew of the revocation
Agent is authorized
Personal notice is required.
to contract with
Since the third persons have been made to
specified persons
believe by the principal that the agent is
authorized to deal with them, they have a right
to presume that the representation continues
to exist in the absence of notification by the
principal.
Innocent third persons dealing with the agent
will not be prejudiced by the revocation before
they had knowledge thereof.
Agent is authorized The fact that the revocation was advertised in
to contract with the a newspaper of general circulation would be
public in general sufficient warning to third persons for the
publication constitutes notice upon everybody
and this is true whether or not such third
persons have read the newspaper concerned.
Art. 1923. The appointment of a new agent for the same business or
transaction revokes the previous agency from the day on which notice
thereof was given to the former agent, without prejudice to the
provisions of the two preceding articles. (1735a)
There is implied revocation of the previous agency when the principal
appoints a new agent for the same business or transaction provided there
is incompatibility.
 But the revocation does not become effective as between the
principal and agent until it is in some way communicated to the
latter.
 The rights of third persons who acted in good faith and without
knowledge of the revocation will not be prejudiced thereby.
 There is no implied revocation where the appointment of another
agent is not incompatible with the continuation of a like authority
in the first agent.
No substitution of counsel of record is allowed unless the following
essential requisites occur:
1. There must be a written request for substitution
2. It must be filed with the written consent of the client
3. It must be with the written consent of the attorney to be substituted
4. In case the consent of the attorney to be substituted cannot be
obtained, there must be at least a proof of notice that the motion
for substitution was served on him in the manner prescribed by the
RoC.
The first counsel may not be presumed substituted by a new counsel
merely from the filing of a formal appearance by the latter.
Art. 1924. The agency is revoked if the principal directly manages the
business entrusted to the agent, dealing directly with third persons.
(n)
Unless the only desire of the principal is for him and the agent to manage
the business together, the effect of the direct management of the
business by the principal himself is to revoke the agency for there would
no longer be any basis for the representation previously conferred.
 But if the purpose of the principal is to avoid payment of his agent’s
compensation, the implied revocation is deemed made in bad faith
and cannot be sanctioned without according to the agent the
commission which is due him.
Art. 1925. When two or more principals have granted a power of
attorney for a common transaction, any one of them may revoke the
same without the consent of the others. (n)
As the appointment of an agent by two or more principals for a common
transaction makes them solidarily liable to the agent for all the
consequences of the agency, any one of the principals is granted under
this article the right to revoke the power of attorney without the consent
of the others.
 In a solidary obligation, the act of one is the act of all.
Art. 1926. A general power of attorney is revoked by a special one
granted to another agent, as regards the special matter involved in the
latter. (n)
This article may also apply where the special power is subsequently
granted to the same agent which had a general power.
 The general power is impliedly revoked as to matter covered by the
special power.
 A special power naturally prevails over a general power.
It is indispensable that notice of revocation be communicated in some
way to the agent.
Art. 1927. An agency cannot be revoked if a bilateral contract depends
upon it, or if it is the means of fulfilling an obligation already
contracted, or if a partner is appointed manager of a partnership in the
contract of partnership and his removal from the management is
unjustifiable. (n)
Exceptions to Art. 1920:
1. When the agency is created not only for the interest of the principal
but also for the interest of third persons
2. When the agency is created for the mutual interest of both the
principal and the agent.
In either case, the agency is deemed as one coupled with an interest.
 It becomes part of another obligation or agreement.
 The agency cannot be revoked by the sole will of the principal as
long as the interest of the agent or of a third person subsists
because it is not solely the rights if the principal which are affected.
o However, an irrevocable power of attorney is obligatory only
on the principal who executed the agency. It cannot affect one
who is not a party thereto.
Art. 1927 mentions of three instances of irrevocability.
An agency coupled with an interest cannot be terminated by the sole will
of the principal although it is so revocable after the interest ceases.
 It is essential that the interest of the agent shall be in the subject
matter of the power conferred and not merely an interest in the
exercise of the power because it entitles him to compensation
therefor.
 An agency is coupled with an interest where:
 o The agent has parted with value or incurred liability at the
principal’s request, looking to the exercise of the power as the
means of reimbursement or indemnity.
o The interest in the thing concerning which the power is to be
exercised arises from an assignment, pledge, or lien created
by the principal with the agent being given the power to deal
with the thing in order to make the assignment, pledge, or lien
effectual.
 The fiduciary relationship is replaced by material consideration
which bars the removal or dismissal of the agent on the ground of
loss of trust and confidence.
 As to what constitutes sufficient interest, it must be a present
interest in the subject matter itself.
o An interest in the proceeds of the power’s exercise as
compensation is not sufficient.
o An agent’s interest in earning his agreed compensation is an
ordinary incident of agency, and neither a contract that the
principal will not revoke nor a contract that the agent can
protect his rights to earn commission in spite of revocation
will deprive the principal of control over acts to be done by
the agent on his behalf.
o The agent’s remedy is to sue for breach of contract if the
principal terminates their contract.
Whether an interest which will make an agency irrevocable exists in a
particular case is to be determined from the entire agreement and from
the facts and circumstances.
 The terminology used by the parties is not controlling.
 Even though an agency is made in terms irrevocable, that fact will
not prevent its revocation by the principal where the agency or
power is not coupled with interest.
 Nor will the fact of a stipulation in the instrument that the intention
of the grantor of the power is that it shall be “construed as a power
of attorney coupled in the interest of the subject matter thereof”
prevent its revocation.
 In the second case, also according to Mechem, there is a power or
authority coupled with interest, which is irrevocable by the
principal, whether by any act during his lifetime or by his death.
 A contrary view according to the Restatement of Agency is that
neither type of power is revocable by the principal, whether during
his lifetime or by his death.
o The Restatement uses the term power given as security “to
cover both types of cases.”
o De Leon: the position taken by the Restatement would seem
to be a commendable one, for the relation of trust and
confidence which is supposed to stand in the way of absolute
irrevocability of an agent’s appointment is affected adversely
as much by one type of power as it is by the other. In both
cases, the agent acts for himself and not on behalf of the
principal.
Persons with a proprietary interest in the subject matter of their agency
are not true agents at all.
 It is said that such an agency merely differs from other types in that
it is irrevocable.
o However, that very fact negates the possibility that it could be
an agency relation at all.
 This is the case since one of the hallmarks of the agency
relation is that the principal must retain control over the
agent concerning the object of his agency.
 If the principal cannot terminate the relation, he has
surrendered that degree of control which an agency
requires.
 If the power holder holds an interest for the benefit of a
person other than the creator of the power, he is not
the creator’s agent.

Revocability of an agency coupled with an interest

A contract not to revoke the agency only abridges the

right of the principal to revoke, and not his power to
revoke.
Where there
But where the authority given to the agent is
is no just
supplemented with an interest, the rule is that both
cause
the right and the power to revoke without the
agent’s consent is taken away, and a purported
revocation can have no effect unless by express
provision that the authority remains revocable.
Coupled with an interest or not, the authority can be
revoked for a just cause.

The irrevocability of a power of attorney may not be

Where there
used to shield the perpetration of acts in bad faith,
is just cause
breach of confidence, or betrayal of trust by the
agent for that would amount to holding that a power
coupled with an interest authorizes the agent to
commit frauds against the principal.

The agent’s power may be given as security without transferring to the

agent any interest in the subject matter of the agency, or he may be given,
in addition, an interest in the subject matter of the agency.
 In the first case, according to Mechem, there is a power or authority
given as security, which, though irrevocable during the principal’s
lifetime, is revoked by his death.
2. Withdrawal
3. Death
4. Civil Interdiction
5. Insanity
6. Insolvency
7. Dissolution
8. Accomplishment
9. Expiration