G.R. No. 174978, July 31, 201
G.R. No. 174978, July 31, 201
However, it must be written when the law requires a specific form. Specifically, Article 1874 of the Civil
Code provides that the contract of agency must be written for the validity of the sale of a piece of land
or any interest therein. Otherwise, the sale shall be void. A related provision, Article 1878 of the Civil
Code, states that special powers of attorney are necessary to convey real rights over immovable
properties. Sally Yoshizaki v. Joy Training Center of Aurora, Inc., G.R. No. 174978, July 31, 2013.