Short answer. No. Article 1894 says the responsibility of two or more agents, even if appointed simultaneously, is not solidary unless solidarity was expressly stipulated. Without that express agreement, each agent answers only for their own default, not for the failures of the others.
What the law says
The responsibility of two or more agents, even though they have been appointed simultaneously, is not solidary, if solidarity has not been expressly stipulated.
Civil Code, Article 1894 — Liability of Several Agents Not Solidary. Read the full provision →
Simultaneous appointment does not create solidarity by itself
It would be reasonable to assume that appointing several agents at once for the same task automatically makes them jointly answerable for each other's failures, but Article 1894 rejects that assumption. It states plainly: "the responsibility of two or more agents, even though they have been appointed simultaneously, is not solidary, if solidarity has not been expressly stipulated." The timing of the appointment — all three at once — does not, by itself, create the kind of liability where each agent could be made to answer for the whole obligation.
Express stipulation is what it takes
The article requires that solidarity be expressly stipulated before it applies. This means the principal and the agents would have needed to actually agree, in clear terms, that each agent would be solidarily responsible with the others — not something the law will infer simply because they were appointed together, work on the same matter, or even share overlapping duties. Since you say you never stated they were solidarily liable, that express stipulation is missing from your arrangement.
What this means when one agent fails to perform
Without an express agreement on solidarity, each agent's responsibility is generally several — meaning each one answers individually for their own performance or default, not for what the others did or failed to do. If one of your three agents failed to perform their part of the task, you cannot look to the other two agents to make up for that specific failure simply because they were appointed at the same time; your recourse for that particular default runs against the agent who actually failed.
What you can do going forward
If you want future appointments of multiple agents to carry joint-and-several responsibility for the whole undertaking, the article tells you exactly what is needed: an express stipulation to that effect, stated clearly in the agency agreement itself. Absent that language, you should expect to deal with each agent's performance and any failures separately, rather than treating the group as a single unit that stands or falls together.
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.
- Edwin Alacon Atienza vs. TKC Heavy Industries Corporation and Leon Tio, G.R. No. 217782, June 23, 2021 — read the decision on LawPhil →