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II. QUASI-DELICT
A. ELEMENTS
Daywalt v. La Corporacion de los Padres A!stinos "ecoletos# et al
FACTS
In 1902, Endencia executed a contract whereby she obligated herself to convey to
plaintiff a tract of land. It was agreed that a deed should be executed as soon as the title to the
land should be perfected and a Torrens certificate should be produced therefore in the nae of
Endencia. True enough the decree had been obtained but the Torrens certificate was not issued
until later. !ll the sae, the parties entered into another contract with a view to carrying the
original agreeent "i.e. 1902 contract# into effect. $till, a third agreeent was entered into
between the parties in 1909% this tie Endencia proised that upon receiving the Torrens title,
she will iediately deliver the sae to &aywalt. In tie, the Torrens certificate was issued.
'aplessly for the plaintiff, Endencia now becae reluctant to turn over the sae for the reason
that it was not her intention to sell so large an aount of land as what was found by the official
survey. Eventually, the controversy(one different fro this case(had reached the $upree
)ourt which )ourt found for &aywalt% the )ourt ordered Endencia to convey the whole tract to
&aywalt.
*a )orporacion de los +adres ecoletos, is a religious corporation, who owned an
estate on the sae island iediately ad-acent to the land which Endencia had sold to &aywalt
( for any years the ecoletos athers had aintained large herds of cattle on the estate.
ather $an/, the person in charge with the fars anageent, had long been well acuainted
with Teodorica Endencia and exerted over her an influence and ascendency due to his religious
character as well as to the personal friendship which existed between the. Teodorica appears
to be a woan of little personal force, easily sub-ect to influence, and upon all the iportant
atters of business was accustoed to see, and was given, the advice of father $an/ and
other ebers of his order. 'e was fully aware of the existence of the contract of 1902 as well
as of the later iportant developents connected with the history of that contract and the
contract substituted successively for it. 3hen the Torrens certificate was finally issued in 1909,
Endencia delivered it for safeeeping to the defendant corporation where it reained in the
custody and under the control of +. 4uan *abarga. 3hat is ore, ather $an/ entered into an
arrangeent with Endencia whereby large nubers of cattle belonging to the defendant
corporation were to be pastured upon said land during a period extending fro 4une 1, 1909, to
5ay 1, 1916.
+laintiff &aywalt sued defendant *a )orporacion, in part, for daages for wrongful
interference in the perforance of the contract.
ISSUE
3hether the act of defendant *a )orporacion in advising Endencia to abstain fro carrying on
with the contract constituted a tort.
HOLDING
N$. !rticle 1902 of the )ivil )ode declares that any person who by an act or oission,
characteri/ed by fault or negligence, causes daage to another shall be liable for the daage
so done. Ignoring so uch of this article as relates to liability for negligence, we tae the rule to
be that a person is liable for daage done to another by any culpable act% and by 7culpable act7
we ean any act which is blaeworthy when -udged by accepted legal standards. The idea
thus expressed is undoubtedly broad enough to include any rational conception of liability for
the tortious acts liely to be developed in any society.
The fact that the officials of defendant *a )orporacion ay have advised Endencia notto carry the contract into effect would not constitute actionable interference with such contract. Itay be added that when one considers the hardship that the ultiate perforance of thatcontract entailed on the vendor, and the doubt in which the issue was involved ( to the extentthat the decision of the )ourt of the irst Instance was unfavorable to the plaintiff and the$upree )ourt itself was divided ( the attitude of the defendant corporation, is not difficult tounderstand. To our ind a fair conclusion on this feature of the case is that father 4uan *abargaand his associates believed in good faith that the contract could not be enforced and thatTeodorica would be wronged if it should be carried into effect. !ny advice or assistance whichthey ay have given was, therefore, propted by no ean or iproper otive. It is not, in ouropinion, to be denied that Teodorica would have surrendered the docuents of title and givenpossession of the land but for the influence and proptings of ebers of the defendantscorporation. 8ut we do not credit the idea that they were in any degree influenced to the givingof such advice by the desire to secure to theselves the paltry privilege of gra/ing their cattleupon the land in uestion to the pre-udice of the -ust rights of the plaintiff.