Unilateral Promise to Sell Insufficient for Land Sale Title Transfer

A contract for the sale of land, concluded by a promise to sell signed by the seller alone, was deemed not to transfer ownership to the purchaser upon acceptance, as the requirement for a bilateral instrument reflecting the mutual consent of both parties was not met. The court reasoned that while an unqualified promise to sell signed by the seller could constitute a unilateral commitment, the formation of the sale itself, which requires the convergence of the will of both the seller and the purchaser, necessitated a formal bilateral act, and the unilateral document, lacking the buyer's signature, was insufficient to perfect the transfer of title.