Short answer. Yes, if you have genuinely taken over — the agency is revoked where the principal directly manages the business entrusted to the agent and deals directly with third persons himself. Keeping an eye on your agent is not the same thing, and the people he was dealing with still need to be told.
What the law says
The agency is revoked if the principal directly manages the business entrusted to the agent, dealing directly with third persons.
Civil Code, Article 1924 — Implied Revocation by Direct Management. Read the full provision →
Conduct can revoke as clearly as a letter
You do not have to say the words. Stepping in and running the matter yourself is inconsistent with someone else running it for you, and the law reads the conduct for what it plainly means. This spares principals who acted rather than wrote — the owner who took over the negotiation, the parent who started collecting the rents in person. What it does not do is leave the agent guessing. He is entitled to know where he stands, and a principal who intends to take over should say so, because an agent who keeps working in good faith may still have claims for what he spent and what he did.
Both halves of the test
The article asks for two things together: that you directly manage the business entrusted to the agent, and that you deal directly with third persons. Asking for weekly updates, approving each step, or instructing him more tightly than before does not meet it — that is supervising an agency, not replacing it. Negotiating with the buyer yourself, signing the documents in your own name, collecting the money into your own hands: that is the conduct the article describes. And the takeover must cover the business that was entrusted. Handling one part yourself while the agent continues with the rest revokes nothing beyond what you actually took over.
Third persons still have to be told
An implied revocation is no more visible to outsiders than a written one you never sent. Where the agency was entrusted for the purpose of contracting with specified persons, Art. 1921 provides that the revocation does not prejudice them if they were not given notice. So a counterparty who was never told, and who deals with the agent while you are busy handling a different part of the matter, may still bind you. Taking over the work is what ends the mandate; telling the people it affected is what limits your exposure, and the two steps are easy to confuse.
Closing it cleanly
Write to the agent confirming that you are taking the matter over and from what date. Write to the counterparties saying that they should now deal only with you. Recover the original power of attorney and any documents, keys or property in his hands, and file the revocation wherever the authority was lodged, whether a bank, a registry or a company. Then settle with him: he is entitled to reimbursement of what he properly advanced, and he may lawfully hold on to things connected with the agency until that is paid. Cleaning that up early is what keeps a routine handover from turning into a dispute.
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.
- International Exchange Bank now Union Bank of the Philippines vs. Sps. Jerome and Quinnie Briones and John Doe, G.R. No. 205657, March 29, 2017 — read the decision on LawPhil →
- Farida Yap Bitte and the heirs of Benjamin Bitte, namely Jacob Yap Bitte, Shira Dayanara Yap Bitte, Fatima Yap Bitte and Allan Robert Yap Bitte vs. Spouses Jonas and Rosa Elsa Serrano-Jonas, G.R. No. 212256, December 9, 2015 — read the decision on LawPhil →
- Sunace international Management Services, Inc., vs. National Labor Relations Commission, et al, G.R. No. 161757, January 25, 2006 — read the decision on LawPhil →
- Carlos Sanchez vs. Medicard Philippines, Inc., et al, G.R. No. 141525, September 2, 2005 — read the decision on LawPhil →
Related provisions
- Civil Code, Article 1924 — Implied Revocation by Direct Management
- Civil Code, Article 1921 — Revocation and Specified Third Persons