Goduco v. Castro
REITERATIONFacts
The Antecedents: Herminia Goduco (petitioner) filed a complaint against Maria B. Castro (respondent) for the recovery of sums of money, primarily a commission of P7,500.00. Petitioner alleged that she facilitated the sale of a 100-hectare land in Parañaque, Rizal, for P150,000.00, and that respondent Castro, the true buyer (with Sostenes Campillo as a dummy), deducted her commission from the purchase price. Petitioner also claimed moral damages and attorney's fees due to respondent's refusal to pay and alleged embarrassing treatment. Procedural History: The trial court dismissed the complaint. The Court of Appeals affirmed the dismissal, finding that the deed of sale was in the name of Sostenes Campillo, not respondent Castro, and that the commission was to be paid by the seller as per the authority given by the owner's son-in-law. The appellate court found petitioner's claims to be hearsay and based on surmise and conjecture, noting that the evidence did not establish Castro as the real buyer or Campillo as her dummy. The Petition: Petitioner Goduco appealed to the Supreme Court, arguing that the Court of Appeals erred in not properly appreciating the evidence and accompanying circumstances, specifically referencing a prior case where Maria B. Castro was found to be the sole owner and other subscribers were dummies, implying Campillo was also a dummy.
Issue(s)
Whether the Court of Appeals erred in its appreciation of the evidence presented. Whether Sostenes Campillo was a dummy for Maria B. Castro in the purchase of the land. Whether petitioner Goduco is entitled to a commission from respondent Castro.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, dismissing the complaint against Maria B. Castro.
Ratio Decidendi
On the alleged error of the Court of Appeals in appreciating the evidence: The Supreme Court held that it is not authorized to re-evaluate the evidence when the Court of Appeals has made findings of fact. The Court of Appeals found that the purchaser was Sostenes Campillo, who was financially capable, and not Maria B. Castro. This conclusion was supported by the evidence on record, which the appellate court found unmistakably showed this fact. The Supreme Court is bound by these factual findings. On whether Sostenes Campillo was a dummy for Maria B. Castro: The Supreme Court found no parallelism between the facts of the present case and the cited Marvel Bldg. Corporation case. In the Marvel case, there was evidence showing other stockholders were dummies, which the trial court failed to consider. In the present case, both the trial court and the Court of Appeals found that the evidence did not sustain petitioner's cause of action, including the assertion that Campillo was a dummy. The appellate court's finding that Campillo was not Castro's dummy and was financially capable of making the purchase was based on the evidence presented. On whether petitioner Goduco is entitled to a commission from respondent Castro: The Court found that petitioner's cause of action was based on an alleged transaction where she offered land for sale, which respondent allegedly bought but registered in another's name, and from which she claimed a commission was deducted. However, all these matters were testified to by the petitioner alone and found no corroboration from any other evidence, testimonial or documentary. The documents submitted, such as the deed of sale and the written authority to sell, were against petitioner's assertions. The written authority did not mention petitioner Goduco, and even if she had authority to sell, it did not make the buyer liable for the commission. At most, the owner of the property and the one who promised the commission should be liable. The Court concluded that petitioner's case rested largely on surmise and conjecture, lacking even a minimal measure of preponderance of evidence.
Main Doctrine
A claim for commission based on an alleged brokerage agreement, where the buyer is claimed to have deducted the commission from the purchase price, cannot prosper without sufficient evidence to establish the buyer's liability and the deduction, especially when documentary evidence contradicts the claim and the plaintiff's assertions are based on hearsay.