05. So Ping Bun vs. CA Sept.

21, 1999 5) Private respondent Tiong sent a letter to petitioner ordering

him to vacate the warehouse because Tiong decided to go back
Topic: Business Torts; not legal justification
into the textile business and he needed the warehouse
Petitioner: SO PING BUN immediately for stocks.
Respondent: CA, TEK HUA ENTERPRISES CORP. and MANUEL C.  Petitioner refused to vacate and instead requested formal
TIONG contracts of lease. Chuan & Sons acceded to petitioner's
FACTS: request.

1) Tek Hua Trading Co. entered into 4 lease agreements on 6) In the suit for injunction, private respondents pressed for the
premises located at Binondo, Manila with lessor Dee C. Chuan nullification of the lease contracts between Chuan & Sons and
& Sons Inc. petitioner. They also claimed damages.

 Tek Hua used the areas to store its textiles. The contracts 7) TC: Ruled for respondent, annulling the four contracts of lease
each had a 1-year term. and awarding P500,000 without prejudice to negotiate for the
renewal of their lease contracts.
 They provided that should the lessee continue to occupy the
premises after the term, the lease shall be on a month-to- 8) (On appeal by So Ping Bun) CA: Upheld the trial court. & upon
month basis. MR Modified the decision by reducing the award to P200,000.

2) When the contracts expired, the parties did not renew the ISSUE: W/N So Ping Bun was guilty of tortuous interference of
contracts, but Tek Hua continued to occupy the premises. contract

3) So Pek Giok, managing partner of Tek Hua Trading, died. His HELD: YES, but he is justified.
grandson, petitioner So Ping Bun, occupied the warehouse for  One becomes liable in an action for damages for a
his own textile business, Trendsetter Marketing. nontrespassory invasion of another's interest in the private
4) Lessor Chuan & Sons sent letters addressed to Tek Hua use and enjoyment of asset if:
Enterprises (formerly Tek Hua Trading but with a new board, (a) the other has property rights and privileges with respect
including private respondent Tiong), informing them of the to the use or enjoyment interfered with;
30% rent increase. (b) the invasion is substantial;
(c) the defendant's conduct is a legal cause of the invasion,
 Enclosed in these letters were new lease contracts for and
signing. Chuan & Sons warned that failure of the lessee to (d) the invasion is either intentional and unreasonable or
accomplish the contracts shall be deemed as lack of interest unintentional and actionable under general negligence
on the lessee's part, and agreement to the termination of rules.
the lease.
The elements of tort interference are:
 Private respondents did not answer any of these letters.
Still, the lease contracts were not rescinded. (1) existence of a valid contract;

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 (2) knowledge on the part of the third person of the  Sec. 1314 of the Civil Code categorically provides also that,
existence of contract; and "Any third person who induces another to violate his contract
(3) interference of the third person is without legal shall be liable for damages to the other contracting party."
justification or excuse. Petitioner argues that damage is an essential element of tort
interference, and since the trial court and the appellate court
 In this case, petitioner's Trendsetter Marketing asked Chuan
ruled that private respondents were not entitled to actual,
& Sons to execute lease contracts in its favor, and as a result
moral or exemplary damages, it follows that he ought to be
petitioner deprived respondent corporation of the latter's
absolved of any liability, including attorney's fees. It is true
property right. Clearly, the three elements of tort interference
that the lower courts did not award damages, but this was
above-mentioned are present in the instant case.
only because the extent of damages was not quantifiable.
 A duty which the law of torts is concerned with is respect for
 While we do not encourage tort interferers seeking
the property of others, and a cause of action ex delicto may
their economic interest to intrude into existing
be predicated upon an unlawful interference by one person of
contracts at the expense of others, however, we find
the enjoyment by the other of his private property. This may
that the conduct herein complained of did not
pertain to a situation where a third person induces a party to
transcend the limits forbidding an obligatory award for
renege on or violate his undertaking under a contract.
damages in the absence of any malice.
 It is debated whether interference may be justified where the
 The business desire is there to make some gain to the
defendant acts for the sole purpose of furthering his own
detriment of the contracting parties. Lack of malice,
financial or economic interest. If the impetus of his conduct
however, precludes damages.
lies in a proper business interest rather than in wrongful
motives, it can be said that his act is justified.  But it does not relieve petitioner of the legal liability for
entering into contracts and causing breach of existing ones.
 Gilchrist vs. Cuddy: There is no malice in the interference of
The respondent appellate court correctly confirmed the
a contract when the impulse behind one's conduct lies in a
permanent injunction and nullification of the lease contracts
proper business interest rather than in wrongful motives. A
between Chuan & Sons and Trendsetter Marketing, without
party cannot be a malicious interferer. Where the alleged
awarding damages. The injunction saved the respondents
interferer is financially interested, and such interest motivates
from further damage or injury caused by petitioner's
his conduct, it cannot be said that he is an officious or
interference.
malicious intermeddler.
 In this case, it is clear that petitioner So Ping Bun prevailed
upon Chuan & Sons to lease the warehouse to his enterprise Dispositive: Appeal denied. The decision of the Court of Appeals is
at the expense of respondent corporation. Though hereby affirmed with modification that the award be reduced to
petitioner took interest in the property of respondent P100,000.
corporation and benefited from it, nothing on record
imputes deliberate wrongful motives or malice on him.

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