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QUASI-DELICT
A. ELEMENTS
FACTS
Plaintif Daywalt sued defendant La Corporacion, in part, for damages for wrongful
interference in the performance of the contract.
ISSUE
Whether the act of defendant La Corporacion in advising Endencia to abstain from carrying
on with the contract constituted a tort.
HOLDING
NO. Article 1902 of the Civil Code declares that any person who by an act or
omission, characterized by fault or negligence, causes damage to another shall be liable for
the damage so done. Ignoring so much of this article as relates to liability for negligence, we
take the rule to be that a person is liable for damage done to another by any culpable act;
and by "culpable act" we mean any act which is blameworthy when judged by accepted
legal standards. The idea thus expressed is undoubtedly broad enough to include any
rational conception of liability for the tortious acts likely to be developed in any society.
The fact that the oicials of defendant La Corporacion may have advised Endencia
not to carry the contract into efect would not constitute actionable interference with such
contract. It may be added that when one considers the hardship that the ultimate
performance of that contract entailed on the vendor, and the doubt in which the issue was
involved — to the extent that the decision of the Court of the First Instance was unfavorable
to the plaintif and the Supreme Court itself was divided — the attitude of the defendant
corporation, is not diicult to understand. To our mind 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 efect.
Any advice or assistance which they may have given was, therefore, prompted by no mean
or improper motive. It is not, in our opinion, to be denied that Teodorica would have
surrendered the documents of title and given possession of the land but for the inluence
and promptings of members of the defendants corporation. But we do not credit the idea
that they were in any degree inluenced to the giving of such advice by the desire to secure
to themselves the paltry privilege of grazing their cattle upon the land in question to the
prejudice of the just rights of the plaintif.