G.R. No. 120554, 21 September 1999
Tek Hua Trading Co, through its managing partner, So Pek Giok, entered into four (4) lease agreements with lessor Dee C. Chuan & Sons Inc. (DCCSI) subject to a one-year term and with the condition that should the lessee continue to occupy the premises after the term, the lease shall be on a month-to-month basis. When the contracts expired, the parties did not renew the contracts, but Tek Hua continued to occupy the premises. In 1976, Tek Hua Trading Co. was dissolved but later on formed Tek Hua Enterprising Corp. So Pek Giok, managing partner of Tek Hua Trading, died in 1986. So Pek Gioks grandson, petitioner So Ping Bun, occupied the warehouse for his own textile business, Trendsetter Marketing.
Lessor DCCSI sent letters to Tek Hua Enterprises stating their intention in increasing the rent and enclosed therein were new lease contracts for signing. DCCSI warned that failure of the lessee to accomplish the contracts shall be deemed a lack of interest on the lessees part and agreement to the termination of the lease. Private respondents did not answer any of these letters. Still, the lease contracts were not rescinded. Private respondent Tiong sent a letter to petitioner advising to vacate all the stocks in Tek Hua Enterprising Corp. Warehouse and giving them 14 days to vacate the premises but still petitioner refused to vacate. Petitioner requested formal contracts of the lease with DCCSI in favor of Trendsetter Marketing. So Ping Bun claimed that after the death of his grandfather, So Pek Giok, he had been occupying the premises for his textile business and religiously paid rent. DCCSI acceded to petitioners request. The lease contracts in favor of Trendsetter were executed. Now private respondents pressed for the nullification of the lease contracts between DCCSI and petitioner.
Whether or not So Ping Bun is guilty of tortous interference of a contract.
Damage is the loss, hurt, or harm which results from injury, and damages are the recompense or compensation awarded for the damage suffered. One becomes liable in an action for damages for a nontrespassory invasion of anothers interest in the private use and enjoyment of asset if (a) the other has property rights and privileges with respect to the use or enjoyment interfered with, (b) the invasion is substantial, (c) the defendants conduct is a legal cause of the invasion, and (d) the invasion is either intentional and unreasonable or unintentional and actionable under general negligence rules.
The elements of tort interference are: (1) existence of a valid contract; (2) knowledge on the part of the third person of the existence of a contract; and (3) interference of the third person is without legal justification or excuse.
In the case before us, petitioners Trendsetter Marketing asked DCCSI to execute lease contracts in its favor, and as a result, petitioner deprived the respondent corporation of the latters property right. Clearly, the three elements of tort interference above-mentioned are present in the instant case.
As a general rule, a justification for interfering with the business relations of another exists where the actors motive is to benefit himself. Such justification does not exist where his sole motive is to cause harm to the other. Some authorities believe that it is not necessary that the interferers interest outweigh that of the party whose rights are invaded, and that an individual acts under an economic interest that is substantial, not merely de minimis, such that wrongful and malicious motives are negatived, for he acts in self-protection. Moreover, a justification for protecting one’s financial position should not be made to depend on a comparison of his economic interest in the subject matter with that of others. It is sufficient if the impetus of his conduct lies in a proper business interest rather than in wrongful motives
Where there was no malice in the interference of a contract, and the impulse behind ones conduct lies in a proper business interest rather than in wrongful motives, a party cannot be a malicious interferer. Where the alleged interferer is financially interested, and such interest motivates his conduct, it cannot be said that he is an officious or malicious intermeddler. In the instant case, it is clear that petitioner So Ping Bun prevailed upon DCCSI to lease the warehouse to his enterprise at the expense of the respondent corporation. Though petitioner took interest in the property of the respondent corporation and benefited from it, nothing on record imputes deliberate wrongful motives or malice on him.
Section 1314 of the Civil Code categorically provides also that, Any third person who induces another to violate his contract shall be liable for damages to the other contracting party. Petitioner argues that damage is an essential element of tort interference, and since the trial court and the appellate court ruled that private respondents were not entitled to actual, moral or exemplary damages, it follows that he ought to be absolved of any liability, including attorneys fees.
It is true that the lower courts did not award damages, but this was only because the extent of damages was not quantifiable. While we do not encourage tort interferers seeking their economic interest to intrude into existing contracts at the expense of others, however, we find that the conduct herein complained of did not transcend the limits forbidding an obligatory award for damages in the absence of any malice. The business desire is there to make some gain to the detriment of the contracting parties. Lack of malice, however, precludes damages. But it does not relieve petitioner of the legal liability for entering into contracts and causing a breach of existing ones. The respondent appellate court correctly confirmed the permanent injunction and nullification of the lease contracts between DCCSI and Trendsetter Marketing, without awarding damages. The injunction saved the respondents from further damage or injury caused by petitioners interference.
* Case digest by Paula Bianca B. Eguia, LLB-1, Andres Bonifacio Law School, SY 2017-2018