no.1. Manzano vs Lazaro effective ratification on voidable contracts.

. Vitiated consent does not make the contract unenforceable but merely voidable; remedy is to file a case to annul the contract; voidable and annullable contracts have produces legal effect until annulled by a proper court(art.1390);voidable contracts susceptible of ratification. Facts: MAnzano and petitioner entered a professional services contract. Outline in the contract is their corresponding duties which includes the award of bonuses in the event that the petitioner would win the elections. Indeed, petitioner won the vice mayoralty. Thus, respondent sent a letter to petitioner demanding payment of services and the bonus. Petitioner replied that there must be first an inventory which accdg to petitioners knowledge, is to be prepared by the respondent. Respondent denied it and argued that preparing liquidation papers was not one of the duties outlined for him. Due to non-payment of the petitioner, respondent filed a case for collection of sum of money. Petitioner alleges that there was misrepresentation on the part of respondent and his consent to the contract was vitiated by fraud. Thus there was no perfected contract at all. The RTC rendered judgment in favor of respondent and affirmed by CA. Issue: WON consent vitiated by fraud annuls the contract. Ruling: No. Vitiated consent does not itself makes the contract unenforceable but merely voidable and annullable and it produces legal effect until annulled by a proper court and voidable contracts are susceptible of ratification. In this case, the acts of petitioner is consistent with ratification amounting to an effective ratification.

No.2 Fontana resort vs. spouses