Daywalt v. Corp.

G.R. No. L-13505, 4 February 1919

FACTS:

Teoderica Endencia obligated herself to convey to Geo W. Daywalt a tract of land. The deed should be executed as soon as the tittle of the land is perfected. There was a decree recognizing Teoderica as the owner of land but the Torrens certificate was not issued until later. The parties met immediately upon the entering of the decree and made a new contract.

There was a development of Teoderica’s land as the Torrens title was issued and in view of this development she became reluctant to transfer the whole tract of land asserting that she never intended to sell the large amount of land and that she was misinformed by the area of the land.

After the Torrens title was issued to Teoderica she gave it to the defendant company for safekeeping in which the defendant did so. As Teodorica still retained possession of said property Father Sanz entered into an arrangement with her whereby large numbers of cattle belonging to the defendant corporation were pastured upon said land.

ISSUE:

Whether a person who is not a party to a contract for the sale of land makes himself liable for damages to the vendee, beyond the value of the use and occupation, by colluding with the vendor and maintaining him in the effort to resist an action for specific performance. 

RULING:

The Supreme Court held that the members of the defendant’s corporation, in advising and prompting Teodorica Endencia not to comply with the contract of sale, were actuated by improper and malicious motives.

In 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.

In the case at bar, as Teodorica Endencia was the party directly bound by the contract, it is obvious that the liability of the defendant corporation, even admitting that it has made itself coparticipant in the breach of the contract, can in no even exceed hers.

This leads us to consider at this point the extent of the liability of Teodorica Endencia to the plaintiff by reason of her failure to surrender the certificate of title and to place the plaintiff in possession.

 * Case digest by Denura, Lady Rubyge, LLB-1, Andres Bonifacio Law School, SY 2017-2018

 

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