SC: SPA revoked upon principal's death, subsequent acts void

The Supreme Court (SC) ruled that a Special Power of Attorney (SPA) is automatically revoked upon the death of the principal, rendering subsequent actions by the agent void, with narrow legal exceptions.

Jessica Alova Uberas acted on an SPA granted by her father, Meliton Alova, to mortgage his property in 2003, five years after his death in 1998.

San Miguel Foods, Inc. (SMFI) initiated foreclosure proceedings after Jessica defaulted on a credit line secured by the mortgaged property.

The SC affirmed that the agency ceased with Meliton's death, but partially favored SMFI by validating the mortgage and foreclosure sale concerning Jessica's share of the property.

Previous rulings by the Regional Trial Court (RTC) and Court of Appeals (CA) had conflicting conclusions regarding the validity of the mortgage after Meliton's death, with the RTC considering the wife's conformity and the CA disagreeing.