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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 were 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 to petitioners. In the letter, they said
that they will not sell the land to Mr. Tayag. Instead, they will sell the land to the Lacsons.
 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.
 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:
 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 Mr. Tayag deceived
them into signing the deed of assignment.
 Farmers thought that what they were signing were the receipts, but instead, what
they signed were Deeds of Assignment.
 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:
Whether 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.
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
 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.