Short answer. No. Compromising a case is expressly on the list of acts requiring a special power of attorney. The same clause covers submitting to arbitration, giving up the right to appeal, waiving objections to venue, and abandoning a prescription you have already acquired.
What the law says
Special powers of attorney are necessary in the following cases:
Civil Code, Article 1878 — Acts Requiring a Special Power of Attorney. Read the full provision →
What the law says
To compromise, to submit questions to arbitration, to renounce the right to appeal from a judgment, to waive objections to the venue of an action or to abandon a prescription already acquired
Civil Code, Article 1878 — Acts Requiring a Special Power of Attorney. Read the full provision →
One clause, five separate surrenders
What ties this clause together is that every act in it gives away a right you already hold. To compromise is to trade your claim for less than it might be worth. To renounce the right to appeal from a judgment is to accept a loss as final. To waive objections to the venue of an action is to let the case be heard somewhere you could have resisted. To abandon a prescription already acquired is to hand back a defence that had already matured in your favour. None of these is administration.
Compromise does not carry arbitration with it
Here is the trap in this area, and it is written into the Code a couple of articles later. Art. 1880 provides that a special power to compromise does not authorise submission to arbitration. The two are listed side by side in the same clause, which makes them look interchangeable, and they are not. If you want your agent to be able to agree to arbitration, that authority has to be granted in its own right — a power to settle, however clearly worded, will not reach it.
Prescription already acquired is a defence you own
This item is easy to skim past and expensive to lose. Once a prescriptive period has run in your favour, the resulting defence is yours, and abandoning it revives a claim that had already gone cold. The Code therefore treats giving it up as an act of dominion rather than a procedural choice. An agent handling a dispute for you cannot decide, as a matter of convenience or goodwill, to let that defence go.
What to put in the document
Because each act on the list is treated separately, an instrument that authorises your agent to “represent me in the case” does not obviously reach any of them. Name the acts you actually intend to allow. If you mean your agent to be able to settle, say so; if you also mean them to be able to accept arbitration, say that too. This is general information about what the Code requires, not advice on any particular case or document.
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.
- Reman Recio vs. Heirs of Spouses Aguego and Maria Altamirano, namely Alejandro, et al., all surnamed Altamirano, et al, G.R. No. 182349, July 24, 2013 — read the decision on LawPhil →
- Alvin Patrimonio vs. Napoleon Gutierrez and Octavio Marasigan III, G.R. No. 187769, June 4, 2014 — read the decision on LawPhil →
- Fil-Estate Properties, Inc. vs. Paulino Reyes, et al, G.R. No. 152797, September 18, 2019 — read the decision on LawPhil →
- Cezar Yatco Real Estate Services, Inc., GRD Property Resources, Inc. Gamaliel Pascual, Jr., Ma. Lourdes Limjap Pascual and Aurora Pijuan vs. Bel-air Village Association, Inc. Represented…, G.R. No. 211780, November 21, 2018 — read the decision on LawPhil →
Related provisions
- Civil Code, Article 1878 — Acts Requiring a Special Power of Attorney
- Civil Code, Article 1880 — Compromise vs. Arbitration