Boysaw V Interphil

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The case involves an appeal filed by Solomon Boysaw and Alfredo Yulo, Jr.

from the decision of the


Court of First Instance (CFI) of Rizal, Quezon City, Branch V in Civil Case No. Q-5063. The case was
titled "Solomon Boysaw and Alfredo M. Yulo, Jr., Plaintiffs versus Interphil Promotions, Inc., Lope
Sarreal, Sr. and Manuel Nieto, Jr., Defendants."

The background of the case is as follows:

1. On May 1, 1961, Solomon Boysaw and his manager, Willie Ketchum, signed a contract with
Interphil Promotions, Inc., represented by Lope Sarreal, Sr., for a boxing contest with Gabriel "Flash"
Elorde for the junior lightweight championship of the world.

2. The contract specified that the bout would take place at the Rizal Memorial Stadium in Manila on
September 30, 1961, or within thirty days thereafter if mutually agreed upon. Boysaw was also
prohibited from engaging in any other contest without the written consent of Interphil Promotions, Inc.

3. A supplemental agreement was entered into on May 3, 1961, addressing certain details not
covered by the principal contract.

4. Boysaw fought and defeated Louis Avila in a ten-round non-title bout in Las Vegas on June 19,
1961.

5. On July 2, 1961, Ketchum assigned the managerial rights over Boysaw to J. Amado Araneta. On
September 1, 1961, J. Amado Araneta assigned the managerial rights over Boysaw to Alfredo J.
Yulo, Jr.

6. Yulo, Jr. wrote a letter to Lope Sarreal, Sr. on September 5, 1961, informing him of the managerial
rights transfer and expressing readiness to comply with the boxing contract.

7. The Games and Amusement Board (GAB) held conferences and scheduled the Elorde-Boysaw
fight for November 4, 1961, which was approved by the USA National Boxing Association.

8. Yulo, Jr. refused to accept the change in the fight date, even when Sarreal offered to advance it to
October 28, 1961. Yulo, Jr. communicated with local boxing promoter Mamerto Besa for a possible
promotion of the fight on November 4, 1961.

9. Despite efforts, the Elorde-Boysaw fight as per the May 1, 1961, contract did not materialize.

10. In response to the events, Boysaw and Yulo, Jr. sued Interphil, Sarreal, Sr., and Manuel Nieto, Jr.
for damages, alleging a breach of the boxing contract.

11. The trial faced delays, and Boysaw left the country without informing the court or his counsel. The
trial was reset several times.

12. The trial proceeded in July 1963, and after plaintiffs declined to submit documentary evidence,
the lower court deemed the case submitted.

13. The lower court dismissed the complaint, and the plaintiffs moved for a new trial, which was
denied, leading to this appeal.
The appeal involves the plaintiffs contesting the lower court's decision, which ordered them to pay
damages to the defendants. The case centers around the alleged failure of Interphil and Sarreal,
aided by Nieto, Jr., to honor their commitments under the May 1, 1961 boxing contract.

Issues:
1. Whether or not there was a violation of the fight contract of May 1, 1961; and if there was,
who was guilty of such violation.
2. Whether or not there was legal ground for the postponement of the fight date from September
1, 1961, as stipulated in the May 1, 1961 boxing contract, to November 4,1961,
3. Whether or not the lower court erred in the refusing a postponement of the July 23, 1963 trial.
4. Whether or not the lower court erred in denying the appellant's motion for a new trial.
5. Whether or not the lower court, on the basis of the evidence adduced, erred in awarding the
appellees damages of the character and amount stated in the decision.

Ruling:
(1) The court ruled that there was a violation of the May 1, 1961 fight contract, and the appellant Boysaw himself was
found guilty of such violation. The evidence presented established that Boysaw fought Louis Avila on June 19,
1961, in Las Vegas, Nevada, without the approval or consent of Interphil Promotions, Inc. Appellant Yulo admitted
this fact during the trial.

While the contract did not explicitly prescribe a penalty for such violation, the court emphasized that the absence of a
specified penalty did not grant any party the unbridled liberty to breach the contract without consequences. The court cited
relevant provisions of the Civil Code, stating that those who contravene the terms of their obligations are liable for damages.

The court also highlighted the principle of reciprocal obligations arising from the contract, wherein each party is both a
debtor and a creditor of the other. The power to rescind obligations is implied in reciprocal contracts, allowing the injured
party to seek redress in case of non-compliance by the other party.

Two specific violations were pointed out by the court:

1. **Fight Without Consent:** Boysaw's unauthorized fight with Louis Avila constituted a breach of the
contract, despite the absence of a specified penalty for such actions.

2. **Unauthorized Transfer of Managerial Rights:** The assignment and transfer of Boysaw's


managerial rights, first to J. Amado Araneta and subsequently to appellant Yulo, Jr., without the
knowledge or consent of Interphil, were considered novations of the original contract. The court ruled
that such novations were not valid without the consent of Interphil, and the acquisition of managerial
rights by Yulo, Jr. and Araneta were done without proper authorization.

In summary, Boysaw was found guilty of violating the fight contract by engaging in an unauthorized
bout and by allowing the transfer of managerial rights without the required consent. The court
emphasized that the power to rescind, given to the injured party in reciprocal contracts, justified its
decision regarding the violation of the May 1, 1961 fight contract.

(2) The court ruled that there was a legal ground for the postponement of the fight date from
September 1, 1961, as stipulated in the May 1, 1961 boxing contract, to November 4, 1961.
The appellees (Interphil Promotions, Inc. and others) sought the postponement primarily due
to an injury sustained by Elorde in a recent bout. The court found that the appellees had a
valid justification to renegotiate the original contract, particularly the fight date, and their desire
to postpone the fight date was neither unlawful nor unreasonable.

The court highlighted the following points in support of its ruling:


1. **Justification for Renegotiation:** The appellees had valid reasons, specifically Elorde's
injury, to renegotiate the original contract, including the fight date. The court acknowledged
the appellees' right to seek an adjustment of one particular covenant of the contract under the
circumstances.

2. **Forfeiture of Enforcement Rights:** The court asserted that the appellants (Boysaw and
Yulo) had forfeited any right to enforce the original contract due to their violations of its terms.
The court reasoned that, by virtue of these violations, the appellants had no grounds to insist
on the strict enforcement of the contract.

3. **GAB's Authority and Decision-Making Process:** The court addressed the appellants'
contention that only Manuel Nieto, Jr. made the decision for postponement, allegedly
arrogating to himself the prerogatives of the whole GAB Board. The court found that the
records did not support this contention and that appellant Yulo himself admitted it was the
GAB Board that set the questioned fight date. The court emphasized the presumption that
official duty has been regularly performed and concluded that the decision to set the fight date
on November 4, 1961, was a GAB Board decision and not solely the decision of Manuel
Nieto, Jr.

In summary, the court upheld the legal ground for the postponement of the fight date,
considering the appellees' valid reasons and the appellants' forfeiture of enforcement rights
due to their contractual violations. The court also affirmed the authority of the GAB Board in
making the decision to set the new fight date.

(3)

Ratio:
The evidence established that the contract was violated by appellant boysaw himself when without
the approval or consent of interphil, He fought louis avila on june 19 1961 in las vegas nevada.
Another violation of the contract in question was the assignment and transfer

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