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II.

QUASI-DELICT
A. ELEMENTS

Daywalt v. La Corporacion de los Padres Agustinos Recoletos, 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
name of Endencia. True enough the decree had been obtained but the Torrens certificate was
not issued until later. All the same, the parties entered into another contract with a view to
carrying the original agreement (i.e. 1902 contract) into effect. Still, a third agreement was
entered into between the parties in 1909; this time Endencia promised that upon receiving
the Torrens title, she will immediately deliver the same to Daywalt. In time, the Torrens
certificate was issued. Haplessly for the plaintiff, Endencia now became reluctant to turn
over the same for the reason that it was not her intention to sell so large an amount of land
as what was found by the official survey. Eventually, the controversyone different from this
casehad reached the Supreme Court which Court found for Daywalt; the Court ordered
Endencia to convey the whole tract to Daywalt.
La Corporacion de los Padres Recoletos, is a religious corporation, who owned an
estate on the same island immediately adjacent to the land which Endencia had sold to
Daywalt for many years the Recoletos Fathers had maintained large herds of cattle on the
estate. Father Sanz, the person in charge with the farms management, had long been well
acquainted 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 them.
Teodorica appears to be a woman of little personal force, easily subject to influence, and
upon all the important matters of business was accustomed to seek, and was given, the
advice of father Sanz and other members of his order. He was fully aware of the existence of
the contract of 1902 as well as of the later important developments connected with the
history of that contract and the contract substituted successively for it. When the Torrens
certificate was finally issued in 1909, Endencia delivered it for safekeeping to the defendant
corporation where it remained in the custody and under the control of P. Juan Labarga. What
is more, Father Sanz entered into an arrangement with Endencia whereby large numbers of
cattle belonging to the defendant corporation were to be pastured upon said land during a
period extending from June 1, 1909, to May 1, 1914.
Plaintiff Daywalt sued defendant La Corporacion, in part, for damages for wrongful
interference in the performance of the contract.

ISSUE

Whether the act of defendant La Corporacion in advising Endencia to abstain from carrying
on with the contract constituted a tort.

HOLDING
NO. Article 1902 of the Civil Code declares that any person who by an act or
omission, characterized by fault or negligence, causes damage to another shall be liable for
the damage so done. Ignoring so much of this article as relates to liability for negligence, we
take the rule to be that a person is liable for damage done to another by any culpable act;
and by "culpable act" we mean any act which is blameworthy when judged by accepted
legal standards. The idea thus expressed is undoubtedly broad enough to include any
rational conception of liability for the tortious acts likely to be developed in any society.
The fact that the officials of defendant La Corporacion may have advised Endencia
not to carry the contract into effect would not constitute actionable interference with such
contract. It may be added that when one considers the hardship that the ultimate
performance of that contract entailed on the vendor, and the doubt in which the issue was
involved to the extent that the decision of the Court of the First Instance was unfavorable
to the plaintiff and the Supreme Court itself was divided the attitude of the defendant
corporation, is not difficult to understand. To our mind a fair conclusion on this feature of the
case is that father Juan Labarga and his associates believed in good faith that the contract
could not be enforced and that Teodorica would be wronged if it should be carried into effect.
Any advice or assistance which they may have given was, therefore, prompted by no mean
or improper motive. It is not, in our opinion, to be denied that Teodorica would have
surrendered the documents of title and given possession of the land but for the influence
and promptings of members of the defendants corporation. But we do not credit the idea
that they were in any degree influenced to the giving of such advice by the desire to secure
to themselves the paltry privilege of grazing their cattle upon the land in question to the
prejudice of the just rights of the plaintiff.