G.R. No. L-9356; February 18, 1915
C. S. GILCHRIST, plaintiff-appellee, vs. E. A. CUDDY, ET AL., defendants. JOSE FERNANDEZ ESPEJO and MARIANO ZALDARRIAGA, appellants.

FACTS:
Plaintiff-appellee C. S. Gilchrist, owner of a cinematograph theater in Iloilo, entered into a contract with defendant E. A. Cuddy, owner of the film “Zigomar,” for its lease and exhibition for one week beginning May 26, 1913, for P125. Cuddy later breached the contract and agreed to lease the same film to defendants-appellants Jose Fernandez Espejo and Mariano Zaldarriaga for P350 for the same period. Upon Gilchrist’s application, the Court of First Instance of Iloilo issued, on May 22, 1913, an ex parte mandatory injunction ordering Cuddy to deliver the film to Gilchrist and a preliminary injunction restraining the appellants from exhibiting it. On August 6, 1913, Gilchrist moved to dismiss the complaint as the injunction was no longer necessary. The court granted the dismissal as to Cuddy but allowed the appellants to present evidence to prove that the injunction was wrongfully issued and to claim damages. The trial court found that Cuddy willfully breached his contract with Gilchrist because the appellants offered a higher price, and that the appellants, through correspondence with their Manila agents, knew that Cuddy was the owner and that the film was booked for about six weeks from April 26, thus indicating they knowingly induced the breach. The court dismissed the appellants’ cross-complaint for damages. The appellants appealed, but failed to include Cuddy’s deposition in the record on appeal.

ISSUE:
Whether the appellants are entitled to damages for the alleged wrongful issuance of the preliminary injunction.

RULING:
No. The Supreme Court affirmed the trial court’s dismissal of the appellants’ claim for damages. The Court adhered to the settled rule that when an appellant fails to bring before it all the evidence, as required under Sections 143 and 497(2) of the Code of Civil Procedure, it will rely on the trial court’s findings of fact and review only questions of law. The appellants did not include Cuddy’s deposition in the record. The Court found no compelling reason to excuse this omission, as the existing evidence (Gilchrist’s testimony and Cuddy’s apologetic letter) supported the trial court’s finding of a valid contract and its breach. On the substantive issue, the Court held that a person who knowingly induces another to breach a contract with a third party is liable for damages to that third party. The trial court’s findings established that the appellants, with sufficient knowledge of Cuddy’s prior commitment (though not necessarily of Gilchrist’s specific identity), induced the breach. Therefore, the injunction issued to protect Gilchrist’s contractual right was not wrongful, and the appellants suffered no legal damage from its issuance. The claim for damages was properly denied. The decision of the lower court was affirmed.