Marcos v. Prieto

Summary

Marcos Prieto challenged the validity of real estate mortgage contracts executed by his agent Antonio Prieto, claiming they exceeded the agent's authority under a Special Power of Attorney. The Regional Trial Court dismissed the complaint, finding that even if the agent exceeded authority, Marcos ratified the acts through a written acknowledgment letter. Marcos filed a late appeal, missing the deadline by four days, which the Court of Appeals dismissed via certiorari. The Supreme Court affirmed, ruling that the mortgage contracts were valid under the SPA's express terms, and that Marcos's written ratification made him fully liable under Civil Code Article 1898. The Court emphasized that ratification validates unauthorized acts as if the principal performed them directly, and that procedural rules regarding appeal deadlines must be strictly followed as they are jurisdictional requirements.