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JOSE V. LAGON v. CA

FACTS:

Petitioner Jose Lagon purchased two parcels of land located in Sultan Kudarat from the estate of Bai Tonina Sepi through an intestate court. Private respondent Menandro Lapuz filed a complaint for torts and damages against petitioner, claiming that he had a contract of lease with Bai Tonina Sepi for three parcels of land and that petitioner induced the heirs to sell the property to him, violating his leasehold rights. Petitioner denied inducing the sale and argued that there was no lease contract covering the property when he purchased it. The trial court ruled in favor of private respondent and ordered petitioner to pay damages. Petitioner appealed the decision to the Court of Appeals.

ISSUES:

  1. Whether the purchase by petitioner of the subject property during the supposed existence of private respondent's lease contract constituted tortious interference under Article 1314 of the New Civil Code.

  2. Whether private respondent is precluded from recovering due to laches.

  3. Whether petitioner is liable for actual damages and attorney's fees.

  4. Whether the petitioner's counterclaims should be upheld.

RULING:

  1. Tortious Interference The Supreme Court ruled that the petitioner did not commit tortious interference. The Court held that the petitioner’s purchase of the property did not meet all elements of tortious interference, particularly knowledge of the contract and malice or bad faith on the part of the petitioner.

  2. Laches The Court deemed it unnecessary to delve into the issue of laches in light of its ruling on tortious interference.

  3. Liability for Damages and Attorney's Fees The Court found no basis to hold the petitioner liable for actual damages and attorney's fees, highlighting the absence of malice or bad faith on the part of the petitioner.

  4. Counterclaims The Court affirmed the trial court and Court of Appeals' decision to dismiss the petitioner's counterclaims for lack of proof and legal bases.

PRINCIPLES:

  1. Article 1314, Civil Code Third parties who induce another to violate his contract are liable for damages if all elements of tortious interference are present.

  2. Elements of Tortious Interference (a) Valid contract, (b) knowledge by the third party, and (c) interference without legal justification or excuse.

  3. Prima Facie Evidence of Notarized Documents A notarized document is prima facie evidence of its contents until proven otherwise by clear, convincing evidence.

  4. Damnum Absque Injuria Damage without legal injury cannot be remedied by law. The law offers no relief for losses that do not result from a legal wrong.

  5. Attorney's Fees May be awarded only when stipulated or provided by law, with clear factual and legal bases.

  6. Actual and Moral Damages Must be proven with reasonable certainty and must result from a wrongful act.