DAYWALT v LA CORPORACION DE LOS PADRES AGUSTINOS RECOLETOS

Facts: in 1902, Teodorica Endencia executed a contract whereby she obligated herself to convey to Geo W. Daywalt
a 452-hectare parcel of land for P 4000. They agreed that a deed should be executed as soon as Endencia’s title to
the land was perfected in the Court of Land Registration and a Torrens title issued in her name. When the Torrens
title was issued, Endencia found out that the property measured 1248 hectares instead of 452 hectares, as she
initially believed. Because of this, she became reluctant to transfer the whole tract to Daywalt, claiming that she
never intended to sell so large an amount and that she had been misinformed as to its area. Daywalt filed an action
for specific performance. The SC ordered Endencia to convey the entiret act to Daywalt. Meanwhile, La Corporacion de
los Padres Agustinos Recoletos (Recoletos), was a religious corp., w/c owned an estate immediately adjacent to the
property sold by Endencia to Daywalt. It also happened that Fr. Sanz, the representative of the Recoletos, exerted
some influence and ascendancy over Endencia, who was a woman of little force and easily subject to the influence
of other people. Fr. Sanz knew of the existence of the contracts with Daywalt and discouraged her from conveying the
entire tract. Daywalt filed an action for damages against the Recoletos on the ground that it unlawfully
induced Endencia to refrain from the performance of her contract for the sale of the land in question and to
withhold delivery of the Torrens title. Daywalt’s claim for damages against the Recoletos was for the huge sum of P
500000 [in the year 1919], since he claims that because of the interference of the Recoletos, he failed to
consummate a contract with another person for the sale of the property and its conversion into a sugar mill.

Issue: whether Recoletos is liable to Daywalt?

Held: No, it is not liable. The stranger who interferes in a contract between other parties cannot become more
extensively liable in damages for the non-performance of the contract than the party in whose behalf he
intermediates. Hence, in order to determine the liability of the Recoletos, there is first a need to consider the liability
of Endencia to Daywalt. The damages claimed by Daywalt from Endencia cannot be recovered from her, first,
because these are special damages w/c were not w/in the contemplation of the parties when the contract was made,
and secondly, these damages are too remote to be the subject of recovery. Since Endencia is not liable for damages
to Daywalt, neither can the Recoletos be held liable. As already suggested, by advising Endencia not to perform the
contract, the Recoletos could in no event render itself more extensively liable than the principal in the contract.