Title
Daywalt vs. La Corporacion de los Padres AgustiNo.Recoletos
Case
G.R. No. 13505
Decision Date
Feb 4, 1919
Teodorica sold land to Daywalt; title discrepancy led to litigation. Religious corporation used land, paying rent. Court awarded P2,497 for use, denied P500,000 claim for contract interference.
A

Case Digest (G.R. No. 13505)

Facts:

GEO. W. DAYWALT, plaintiff and appellant, sued LA CORPORACION DE LOS PADRES AGUSTINOS RECOLETOS, defendant and appellee, for damages arising out of the vendor’s delayed delivery of title and the defendant’s use of the land; the transactions occurred in the Province of Mindoro between 1902 and 1914 and the decision was rendered February 4, 1919. In 1902 Teodorica Endencia, an unmarried resident of Mindoro, contracted to convey a tract in the barrio of Mangrarin, municipality of Bulalacao (now San Jose), and the parties executed a deed dated August 16, 1906 fixing the price at P4,000 and describing an area stated as 452 hectares and a fraction; a later agreement of October 3, 1908 provided that, upon issuance of the Torrens certificate, the title should be delivered to a bank to be forwarded for delivery to Daywalt upon payment of a balance of P3,100. A decree recognizing Teodorica’s ownership was entered in August 1906 and the Torrens certificate was eventually issued in 1909, whereupon Teodorica deposited it with the defendant corporation in Manila under the custody of Padre Juan Labarga. During 1909, after the corporation sold its San Jose estate and moved about 2,368 head of cattle to adjacent lands, Father Isidoro Sanz, acting for the corporation and having long influenced Teodorica, arranged with her for the corporation’s cattle to pasture upon the property from June 1, 1909 to May 1, 1914. An official survey disclosed a discrepancy in the land area, and Teodorica resisted delivery, leading Daywalt to file for specific performance; this Court ultimately ordered specific performance in a prior proceeding which became finally effective in early 1914. In the action now reviewed Daywalt alleged two causes: first, damages of P24,000 for use and occupation during the period the corporation pastured its cattle, for which the trial court found liability and awarded P2,497, and second, exemplary damages of P500,000 for maliciously inducing Teodorica to withhold performance and to defend the suit; the defendant did not appeal the award for use and occupation but the plaintiff appealed, and the trial court rejected the claim for the large consequential damages.

Issues:

Was the award of P2,497 for the use and occupation of the land during June 1, 1909 to May 1, 1914 insufficient and should it be increased; and was the defendant corporation liable for the special and consequential damages of P500,000 alleged to have resulted from its interference with the vendor’s performance?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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