Esteban Barretto v. Manila Railroad Co.

Summary

This 1924 Supreme Court case involved a contract dispute over the sale of real property where plaintiff Barretto claimed Manila Railroad Co. agreed to purchase his house for P3,700 but refused payment after he executed the deed. The railroad company successfully defended using the Statute of Frauds, arguing the oral contract was unenforceable. The Supreme Court reversed the lower court's judgment favoring plaintiff, holding that mere delivery of the deed to the defendant's agent without intention to transfer title until payment, followed by return of the deed to plaintiff, was insufficient part performance to remove the contract from the Statute of Frauds. The case establishes important precedent regarding what constitutes adequate part performance in real property sales contracts under Philippine law.