Petrona Tacalinar v. Lorenzo Corro y Manalili

Summary

This case involved a property dispute over whether the 1898 transaction for Santo Nino Hacienda was a lease or sale. The heirs of Leoncio Alfon claimed the property was merely leased to Lorenzo Corro, while Corro maintained he purchased it. The Supreme Court applied Civil Code provisions on contract confirmation, finding that even if the original sale had defects due to lack of authorization, Alfon's subsequent collection of payment with full knowledge of the transaction constituted implied confirmation under Article 1311. The Court held that confirmation operates retroactively to validate the contract from execution and purges all defects. Alfon's silence during 1902-1903 third-party claim proceedings further estopped the heirs from asserting contrary ownership. The decision affirmed Corro's valid acquisition and his subsequent sale to Juan Perez, establishing important precedent on implied contract confirmation in Philippine jurisprudence.