Daywalt v.

La Corporacin de los Padres Agustinos Recoletos, et al

FACTS:
In 1902, Teodorica Endencia executed a contract with Geo W. Daywalt wherein she
obligated herself to convey to Daywalt a parcel of land in barrio of Mangarin, Bulalacao,
Mindoro that originally measured 452 hectares. They executed a second contract in the
form of a deed of conveyance with a stipulated price fixed at P4, 000.00. It was agreed
upon that Endencia shall deliver to Daywalt the Torrens Title upon receipt through the
method stiulated. In the issuance of the Torrens Title, it was later found out that the said
parcel of land measured to 1,248 hectares instead of 452 hectares. Thus, Endencia
became reluctant to transfer the whole tract to the purchaser asserting. The Court ruled in
favor of Daywalt in obtaining a decree for specific performance; Endencia was ordered to
convey the entire tract of land to Daywalt pursuant to their contract, which was declared
to be in full force and effect. The defendant, La Corporacin de los Padres Agustinos
Recoletos came into the picture when, being a neighbor of Endencia with knowledge on
the existence of Endencias contract with Daywalt, took in custody the Torrens certificate
of the land. When the defendant sold the land adjacent to Endencias land, they entered
into an agreement with Endencia who was still in possession of the land in question
whereby a large numbers of cattle owned by the defendant were pastured in the land.

ISSUES:
1) WON 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 an effort to resist an action for specific performance.
YES
2) WON the damages which Daywalt seeks are too remote and speculative to be the
subject of recovery. YES

HELD:
1) Daywalt argues that because of Father Labargas refusal to deliver the Torrens title,
Daywalts project for the establishment of a sugar enterprise was not actualized.
- The Court believes that the Recoletos Fathers, in advising Endencia not to push through
w/ her contract, acted in good faith. However, they are still held liable as malice in the
sense of ill-will or spite is not essential in cases of interference.
- One who buys something which he knows has been sold to some other person can
be restrained from using that thing to the prejudice of the person having the prior
and better right. In this case, the Recoletos Fathers used the property with notice that
Daywalt had a prior and better right.
- HOWEVER: The stranger to the contract cannot become more extensively liable in
damages for the
non-performance of the contract than the party in whose behalf he intermeddles. In
the instant case, as Endencia was the party directly bound by the contract, it is obvious
that the liability of the defendant corporation can in no event exceed hers.
2)
- The kind of damage contemplated is a special damage (as opposed to an ordinary
damage). Special damages are found in cases where some external condition, apart from
the actual terms to the contract, exists or intervenes, as it were, to give a turn to affairs
and to increase damage in a way that the promisor, without actual notice of that external
condition, could not reasonably be expected to foresee.
- In the case at bar, the damages Daywalt is praying for cannot be recovered from
Endencia because these are special damages which were not within contemplation of
the parties when the contract was made. Moreover, said damages are too remote to be
the subject of recovery.