I expressly forbade my agent from appointing a substitute, but he named one anyway — are that substitute's actions binding on me at all?

The default: an agent may appoint a substitute unless told not to

Article 1892 starts from a permissive default: the agent may appoint a substitute if the principal has not prohibited him from doing so. Without an express prohibition, appointing a substitute is generally within the agent's authority. Your situation is different from this default, because you did expressly forbid it, which is exactly the condition the article treats differently from the ordinary case.

Where substitution is allowed, the agent can still answer for the substitute

Even in the ordinary case where substitution is not prohibited, the article does not leave the principal without protection: it can still make the agent responsible for the acts of the substitute in certain situations, such as when the agent was not given the power to appoint a substitute at all, or was given that power without naming a person and chose someone notoriously incompetent or insolvent. That liability rule, however, presumes the substitute's acts otherwise stand; it is not the rule that applies to you.

An express prohibition changes the outcome entirely

Article 1892 draws a sharp line once there is an express prohibition: all acts of the substitute appointed against the prohibition of the principal shall be void. This is not a question of the agent being liable to you for what the substitute did. The substitute's acts themselves are void, meaning they do not take legal effect against you at all.

What this means for the substitute's actions

Because you expressly forbade your agent from appointing a substitute, and the agent named one anyway, Article 1892 places this squarely under the void-acts rule rather than the agent-liability rule. The substitute's actions are not binding on you; they are treated as though they carry no legal effect, precisely because they were done in defiance of your express prohibition, not merely without your knowledge or after the fact.

Cases citing this provision

These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.

• Sps. May S. Villaluz and Johnny Villaluz, Jr. vs. Land Bank of the Philippines and the Registrar of Deeds for Davao City, G.R. No. 192602, January 18, 2017 — read the decision on LawPhil →
• Corazon L. Escueta, et al. vs. Rufina Lim, G.R. No. 137162, January 24, 2007 — read the decision on LawPhil →

Related provisions

• Civil Code, Article 1892 — Appointment of a Substitute