Tang Ah Chan v. Eduardo B. Gonzalez

Summary

Tang Ah Chan sought rescission of a P106,000 land sale contract, claiming the broker Helen Dahlke misrepresented the property location. The Supreme Court affirmed the trial court's denial of rescission, finding that Tang Ah Chan had ratified the contract through his post-sale conduct. Key evidence included Tang Ah Chan's possession of accurate property plans during negotiations, his building permit application correctly describing the location, negotiations for sea wall construction consistent with waterfront property, personal presence during land surveys where boundaries were explained, and payment of mortgage interest for months without protest. The Court applied Civil Code provisions on ratification (Articles 1309, 1311, 1313), holding that implied ratification through conduct with knowledge of the true transaction purges all contract defects and extinguishes nullity actions. The decision establishes important precedent on contract ratification and the waiver of rescission rights through post-contractual conduct demonstrating acceptance of the agreement's terms.