G.R. No. 119107, 18 March 2005
Petitioner Jose Lagon purchased from the estate of Bai Tonina Sepi, through an intestate court, two parcels of land located at Tacurong, Sultan Kudarat. A few months after the sale, private respondent Menandro Lapuz filed a complaint for torts and damages against petitioner before the Regional Trial Court (RTC) of Sultan Kudarat.
Private respondent claimed that he entered into a contract of lease with the late Bai Tonina Sepi Mengelen Guiabar over three parcels of land (the property) in Sultan Kudarat, Maguindanao beginning 1964. One of the provisions agreed upon was for private respondent to put up commercial buildings which would, in turn, be leased to new tenants. The rentals to be paid by those tenants would answer for the rent private respondent was obligated to pay Bai Tonina Sepi for the lease of the land. The lease contract ended but since the construction of the commercial buildings had yet to be completed, the lease contract was allegedly renewed.
When Bai Tonina Sepi died, private respondent started remitting his rent to the court-appointed administrator of her estate. But when the administrator advised him to stop collecting rentals from the tenants of the buildings he constructed, he discovered that petitioner, representing himself as the new owner of the property, had been collecting rentals from the tenants. He thus filed a complaint against the latter, accusing petitioner of inducing the heirs of Bai Tonina Sepi to sell the property to him, thereby violating his leasehold rights over it.
In his answer to the complaint, petitioner denied that he induced the heirs of Bai Tonina to sell the property to him, contending that the heirs were in dire need of money to pay off the obligations of the deceased. He also denied interfering with private respondents leasehold rights as there was no lease contract covering the property when he purchased it; that his personal investigation and inquiry revealed no claims or encumbrances on the subject lots
Whether or not the purchase by Lagon of the subject property, during the supposed existence of the private respondent’s lease contract with the late Bai Tonina Sepi, constituted tortuous interference for which Lagon should be held liable for damages.
No, the interference of Lagon was with a legal justification (in furtherance of a personal financial interest) and without bad faith
The elements of Tortuous Interference with contractual relation are: (1) Existence of a valid contract; (2) Knowledge on the part of the third person of the existence of the contract; (3) Interference of the third person without legal justification or excuse.
As regard to the first element, the existence of a valid contract must be duly established. In the given case the Court ruled that the notarized copy of lease contract presented in court appeared to be an incontestable proof that Bai Tonin Sepi and private respondent renewed their contract. The second element on the other hand, requires that there be knowledge on the part of the interferer that the contract exists. In this case, Lagon had no knowledge of the lease contract as he even conducted his own personal investigation and inquiry, and unearthed no suspicious circumstance that would have made a cautious man probe deeper and watch out for any conflicting claim over the property; that an examination of the entire property title bore no indication of the leasehold interest of private respondent and that even the registry of property had no record of the same. As to the third element, a party may be held liable only when there was no legal justification or excuse for his action or when his conduct was stirred by a wrongful motive. To sustain a case for tortuous interference, the other party must have acted with malice or must have been driven by purely impious reasons to injure the other. In the case, even assuming that private respondent was able to prove the renewal of his lease contract with Bai Tonina Sepi, the fact was that he was unable to prove malice or bad faith on the part of petitioner in purchasing the property. Therefore, the claim of tortuous interference was never established.
* Case digest by Aisha Mie Faith M. Fernandez, LLB-1, Andres Bonifacio Law School, SY 2017-2018