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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 &aywa lt% 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 i portant developents connected with the history of that contract and the contract substituted successively for it . 3hen the Torrens certif icate was finally is sued 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, ath er $an/ entered into an arrangeent wi th Endenc ia whereby lar ge nubers of cat tle bel onging to the def endant corporation were to be pastured upon said land during a period extending fro 4une 1, 1909, to 5ay 1, 1916. +laint iff &ay wal t sued def endant *a )orpor aci on, in part, for daages for wrongful interference in the perforance of the contract.

Daywalt v. La Corporacion (Quasi-Delict [Elements])

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Page 1: Daywalt v. La Corporacion (Quasi-Delict [Elements])

 

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.

Page 2: Daywalt v. La Corporacion (Quasi-Delict [Elements])

 

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.