Corazon L. Escueta v. Rufina Lim

Summary

Supreme Court affirmed validity of property sale contract between respondent Rufina Lim and petitioners involving hereditary shares in real property. Despite competing sale to Corazon Escueta, the Court found the original contract valid based on meeting of minds, payment of earnest money, and actual delivery through possession. Petitioner Rubio's acceptance of payment constituted ratification even if agent lacked proper authority. The Baloloys' petition for relief from default judgment was properly denied for non-compliance with reglementary period. The case establishes that earnest money serves as proof of contract perfection and that actual delivery transfers ownership, preventing subsequent sales to other parties.