Gutierrez Hermanos v. Engracio Orense

Summary

This case involves the enforceability of a property sale executed by an agent without written authority but subsequently ratified by the principal. Jose Duran sold his uncle Engracio Orense's property to Gutierrez Hermanos under a redemption agreement. When Orense initially denied authorizing the sale, Duran faced estafa charges. However, Orense testified under oath that he had consented to the sale, leading to Duran's acquittal. When Orense later refused to honor the transaction after the redemption period expired, the Supreme Court held that his sworn admission constituted valid ratification under Civil Code provisions on agency and contracts. The Court applied the principle that ratification cures initial nullity and that repeated acknowledgments of consent satisfy legal requirements even without written authority. This decision demonstrates the binding effect of judicial ratification and the application of agency law principles in property transactions.