No to Litigation to Sorrows Caused by Broken Hearts and Promises―SC

May 18, 2022

“A mere breach of a promise to marry is not an actionable wrong, as long as it is not of

such extent as would palpably and unjustifiably contradict good customs…Litigation to
the sorrows caused by a broken heart and a broken promise must be discouraged.”

The Supreme Court reiterated this doctrine as it granted the Petition for Review on
Certiorari assailing the rulings of the Court of Appeals (CA), which reversed the
decision of a Regional Trial Court (RTC) finding petitioner liable for damages to
respondent, her German former fiancé. Petitioner broke up with the respondent after
finding out that the latter lied about his identity and marital status.

In a Decision penned by Justice Marvic M.V.F. Leonen, the Court granted the petition
of Jhonna Guevarra, et al. and deleted the award of actual damages in the amount if
P500,000 to respondent Jan Banach.

Guevarra and Banach met through a pastor, and the latter subsequently courted the
former until they became a couple. Both agreed to get married, with Banach giving
Guevarra P500,000 to buy a lot for their conjugal home.

However, Guevarra broke up with Banach after she found out that he was not a
divorcee, as he led her to believe, but was actually still married to his third wife.

This prompted Banach to sue Guevarra and her parents before the RTC.

The RTC ruled in favor of Banach and awarded moral damages and attorney’s fee. On
appeal, the CA issued a Decision on January 29, 2007 similarly ordering Guevarra and
her parents to return the money under the principle of unjust enrichment. However, it
deleted the awards of moral damages and attorney’s fees, as it ruled that Banach’s
actions were tainted with fraud and deceit, and that he did not have the purest
intentions in expressing his desire to marry Guevarra.

Both parties sought reconsideration of the CA’s 2007 Decision. On July 14, 2014, the
CA issued a Resolution denying the Motions for Reconsideration. The case was then
elevated to the Supreme Court , the main issue being whether or not the Order to
return the P500,000 is proper.

The Court agreed with the CA that Banach’s actions were tainted with fraud and deceit,
and that he did not have the purest intentions in marrying Guevarra. It noted that
Banach lied about his marital status, and even hid his true name from Guevarra.

“These acts suffice to justify the wedding’s cancellation. Finding out that one’s
betrothed is still married to another person, and that they are not who they say they
are, are reasons enough to conclude bad faith…Since
respondent himself did not act in good faith, he cannot claim damages under the New
Civil Code. The unjust enrichment principle under Article 22 only applies if the property
is acquired without legal grounds,” said the Court.

The Court explained that Banach gave the money as a gift to help Guevarra and her
parents with their possible eviction from their home. It added that the money being a
gift, petitioner Guevarra is correct to say that she cannot be compelled to return the
same. (G.R. No. 214016, Guevarra, et al. v. Banach, November 24, 2021) FULL TEXT:
https://sc.judiciary.gov.ph/26981/