Tayag v. Lacson

 Tayag v. Lacson, 

G.R. No. 134971, 

March 25, 2004

DOCTRINE: Where there was no malice in the interference of a contract, and the

impulse behind one’s conduct lies in a proper business interest rather than in wrongful

motives, a party cannot be a malicious interferer.

FACTS:

A group of original farmers individually executed in favour of the Herminio Tayag

separate Deeds of Assignments; assignees assigned respective rights as tenants of the

landholdings, for Php 50.00 per sqm.Herminio Tayag was granted exclusive right to buy

if and when the Respondents Lacson, with concurrence of defendants-tenants who are

a group of original farmers, agreed to sell the property. The defendant-tenants gave a

notice of collective decision to sell all their rights and interests, as tenants/lessees, over

the landholding to the Lacsons.

Tayag filed a complaint against the defendant-tenants and Respondents Lacson

for the court to fix a period within which to pay the agreed purchase price. He prayed for

an Injunction prohibiting, restraining defendant-tenants from rescinding their contracts,

so as to prevent irreparable damages to the petitioner. The defendants alleged that the

money received from him were loans, that they did not know that what they signed was

a Deed of Assignment, that they were led to think that they were signing receipts to their

loans, that such Deed were signed through the employment of fraud, deceit and false

pretenses of Tayag and made them believe that what they signed was a mere receipt

for amounts received by way of loans and that this Deed reflected that they did assign

all their rights and interests in the properties or landholdings they were tilling in favor of

Tayag. That if this is so, assuming arguendo that the documents were voluntarily

executed, the defendant-tenants do not have any right to transfer their interest in the

landholdings they are tilling as they have no right whatsoever in the landholdings, the

landholdings belong to their co-defendants, Lacsons which made the contract null and

void.

The RTC granted Tayag’s prayer for an Injunction. The CA reversed RTC’s

decision and decided against him annulling such injuction.

ISSUES:

Is the Deed of Assignment issued a valid contract?

HELD:

No. We do not agree with the contention of the petitioner that the deeds of

assignment executed by the defendants-tenants are perfected option contracts. An

option is a contract by which the owner of the property agrees with another person that

he shall have the right to buy his property at a fixed price within a certain

time. It is a condition offered or contract by which the owner stipulates with another that

the latter shall have the right to buy the property at a fixed price within a certain time, or

under, or in compliance with certain terms and conditions, or which gives to the owner

of the property the right to sell or demand a sale. It imposes no binding obligation on the

person holding the option, aside from the consideration for the offer.

Until accepted, it is not, properly speaking, treated as a contract. The second

party gets in praesenti, not lands, not an agreement that he shall have the lands, but the

right to call for and receive lands if he elects. An option contract is a separate and

distinct contract from which the parties may enter into upon the conjunction of the

option. Herminio Tayag impleaded the Respondents Lacson as parties defendants

solely on his allegation that the Respondents Lacson induced or are inducing the

defendants-tenants to violate the deeds of assignment, contrary to the provisions of

Article 1314 of the New Civil Code which reads: Art. 1314. Any third person who

induces another to violate his contract shall be liable for damages to the other

contracting party.

In So Ping Bun v. Court of Appeals, we held that for Art. 1314 to apply, the

pleader is burdened to prove the following:

(1) the existence of a valid contract;

(2) knowledge by the third person of the existence of the

contract; and

(3) interference by the third person in the contractual relation without legal justification.

Where there was no malice in the interference of a contract, and the impulse

behind one’s 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 fine, one who is not a party to a contract and who

interferes thereon is not necessarily an officious or malicious intermeddler. The only

evidence adduced by Herminio Tayag to prove his claim is the letter from the

defendants-tenants informing him that they had decided to sell their rights and interests

over the landholding to Respondents Lacson,

- instead of honoring their obligation under the deeds of assignment because, according

to them, Herminio Tayag harassed those tenants who did not want to execute

deeds of assignment in his favor,

- and because the said defendants-tenants did not want to have any problem with the

Respondents Lacson who could cause their eviction for executing with the petitioner the

deeds of assignment as the said deeds are in violation of P.D. No. 27 and Rep. Act No.

6657.

The defendants-tenants did not allege therein that the Respondents

Lacson induced them to breach their contracts with Herminio Tayag. He himself

admitted when he testified that his claim that the respondents induced the defendantsassignees

to violate contracts with him was based merely on what "he heard.