W. M. Tipton v. Mariano Velasco Chua-Chingco

Summary

This 1906 Supreme Court case involved a dispute over a 10-year lease of San Lazaro Hospital property executed by the hospital administrator without proper authority. The trial court found the lease valid based on alleged government ratification through rent collection. The Supreme Court reversed, holding there was no evidence the Government ever collected rent or ratified the lease - only hospital administrators received payments. Applying Civil Code Article 1259, the Court ruled that contracts executed without authority remain permanently void until properly ratified by the principal. The Court distinguished this from the Article 1301 statute of limitations, emphasizing that unauthorized contracts cannot be validated by mere passage of time. The lease was declared valid only for six years (1899-1904) and void thereafter, establishing important precedent on contractual authority and ratification requirements.