In San Miguel Foods, Inc. vs. Alova, et al. (G.R. No. 260071, May 7, 2025), the Supreme Court ruled that a Special Power of Attorney’s (“SPA”) validity automatically ends upon the death of the person who granted it, and any acts carried out by the agent afterward are void, unless the act fell under the exceptions established under Articles 1930 and 1931 of the Civil Code: (1) when the agency was for the parties’ common interest, and (2) when the agent, unaware of the death or agency’s end, contracted with a third party in good faith. Thus:

“Agency is basically personal, representative, and derivative in nature. The authority of the agent to act emanates from the powers granted to him by his or her principal. The agent’s act is the act of the principal if done within the scope of the authority.

Owing to its nature, agency is extinguished by the death of either the principal or the agent. Thus, any act by the agent subsequent to the principal’s death is void ab initio, unless the act fell under the exceptions established under Articles 1930 and 1931 of the Civil Code.”