Tayag v.

Lacson

Parties involved:
Petitioner - Tayag (the person who wants to buy the property)
Respondent - Lacson (owner of the land)
Farmers - the persons who are farming the land of the Lacsons.

FACTS:

The Lacsons own lands in Pampanga. The properties were tenanted agricultural
land which were tenanted by the farmers.
The farmers executed a Deed of Assignment in favor of Petitioner. The Deed of
Assignment states the ff:
o Farmers will assign their rights to the lands to Petitioner in consideration
of P50/sq. meter;
o The P50 will be paid when the legal impediments to the sale of the
property to the petitioner no longer existed.
o The petitioner was granted the exclusive right to buy the property if the
farmers and the Respondents agree to sell the property
Petitioner then started giving various amounts of money to the farmers as partial
payments. The farmers issued receipts.
Petitioner then asked to meet up with the farmers to finalize their deal.
However, the farmers did not show up. Instead, they sent a letter
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to petitioners.
In the letter, they said that they will not sell the land to petitioner. On the contrary,
they said that they will sell the land to respondents instead.
Nagalit si petitioner. Petitioner filed a complaint:
o He asked the court to fix a period w/in which to pay the P50/sq. meter
o He asked the court to issue a writ of preliminary injunction to enjoin:
The farmers from rescinding the Deed of Assignment
The respondents from alienating/encumbering their land
o He also asked for damages because he claims that the respondents
induced the farmers to violate their contracts. (What is relevant to our
lesson!)
Defense of the Respondent:
o They never induced the farmers to violate their contracts with petitioner;
o The farmers had no right to enter into the Deed of Assignments because:

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Kami ay nagtiwala sa inyo, naging tapat at nanindigan sa lahat ng ating napagkasunduan, hindi tumanggap ng ibang
buyer o ahente, pero sinira ninyo ang aming pagtitiwala sa pamamagitan ng demanda ninyo at pagbibigay ng
problema sa amin na hindi naman nagbenta ng lupa.
Kaya kami ay nagpulong at nagpasya na ibenta na lang ang aming karapatan o ang aming lupang sinasaka sa
landowner o sa mga pamilyang Lacson, dahil ayaw naming magkaroon ng problema.
Kaya kung ang sasabihin ninyong itoy katangahan, lalo sigurong magiging katangahan kung ibebenta pa namin sa
inyo ang aming lupang sinasaka, kaya pasensya na lang Mister Tayag. Dahil sinira ninyo ang aming pagtitiwala at
katapatan.

They are not the owners of the land, they are mere land tillers
The deed of assignment is contrary to the CARP Law and other
agrarian laws.
Defense of the Farmers:
o They did not execute any Deed of Assignment
o What actually happened was that they got loans from petitioner and that
petitioner deceived them into signing the deed of assignment.
Farmers thought that what they were signing were the receipts,
pero yun pala Deed of Assignment na pala.
Petitioner presented his evidence: the Deed of assignment, the letter, and the
receipts.
Respondent filed a Motion to Dismiss
RTC - denied the MTD, issued the preliminary injunction
o Respondents appealed the orders
CA - reversed the RTC
o CA enjoined the RTC from proceeding with the civil case. CA said that
the issuance of the preliminary injunction was wrong.
Petitioner appealed. Hence this case.

ISSUE:
w/n the issuance of the preliminary injunction was proper.

HELD: NO!!!

RATIO:
For the court to issue a writ of preliminary injunction, the ff. req. must be
satisfied:
o There must be a clear and unmistakable right;
o A violation of such right;
o There is an urgent necessity for the writ in order to prevent serious
damage.
Injunction is a preservative remedy aimed at protecting substantial rights and
interests. In the absence of a clear legal right, there can be no writ of
preliminary injunction.
In the case at bar, petitioners have no clear legal right:
o The respondents are the owners of the land. Thus, they cannot be enjoined
from encumbering/alienating their own property. As registered owners of
the lands, they can do whatever they want with it except in cases stated in
the law.
o The deed of assignment will not bind the respondents because:
The farmers are not the owners;
The respondents were not privy to the deed of assignment;
Petitioner testified, that he did not meet/know any of the
respondents prior to the filing of the complaint.
The respondents did not consent to the deed of assignment
In fact, they said that the deed of assignment is void
because it violated the CARP law.
The principal relief of asking the court to fix a period wherein the
petitioner will pay the P50 is also not proper (remember that, when
the petitioner filed his complaint, this is what he really wanted).
o In fact, based on the face of the complaint, petitioner has no cause of
action.
Based on the deed of assignment, the lands will be sold only when
there are no legal impediments existing.
According to the petitioner the ff. are the legal impediments:
Respondents have not given their consent to the sale
The DAR have not approved the sale
It is only upon the concurrence of the two events will the petitioner
be obliged to pay the P50.
There is no showing that respondents agreed to the sale or
the approval of the DAR have been obtained.
o Lastly, the respondents were only impleaded because it was alleged
that they induced the farmers to violate the contract. In violation of
Art. 1314 of the NCC (what is relevant to our lesson!)
The elements of tortious interference are as follows:
There is a valid contract
A 3rd party knows the existence of such a contract
The 3rd party interfered with such contract w/o any legal
justification.
The 3rd party must be impelled by malice
o The interference must not be due to:
Proper business interest; or
Because the 3rd party is financially
interested
When such motives impelled the 3rd
party, he cannot be considered a
malicious interferer.
Essentially, the mere fact that a 3rd party interfered in a contractual
relation would not automatically make him a malicious interferer.
In the case, the only evidence presented by the petitioner is the
letter.
However, the letter only said that the farmers decided to
sell the land to the respondents because they were harassed
by petitioner and they would not want to cause any
problems for the respondents who could cause their
eviction because they executed the deed of assignments in
violation of agrarian laws.
In fact, petitioner himself admitted that he just heard that
the respondents induced the farmers.
Even if the respondents received an offer from the farmers, they
cannot be enjoined from entertaining/negotiating with the farmers.
The respondents were not even expected to warn the farmers that if
they execute the deed of assignments, they would violate the
agrarian laws.



Additional info in case sir asks:
o From the pleadings of the petitioner, it is quite evident that his purpose in
having the defendants-tenants execute the Deeds of Assignment in his
favor was to acquire the landholding without any tenants thereon, in the
event that the respondents agreed to sell the property to him.
o By assigning their rights and interests on the landholding under the deeds
of assignment in favor of the petitioner, the defendants-tenants thereby
waived, in favor of the petitioner, who is not a beneficiary under Section
22 of Rep. Act No. 6657, their rights of preemption or redemption under
Rep. Act No. 3844.
o Instead of acquiring ownership of the portions of the landholding
respectively tilled by them, the defendants- tenants would again become
landless for a measly sum of P50.00 per square meter. The petitioners
scheme is subversive, not only of public policy, but also of the letter and
spirit of the agrarian laws.