Case Digest (G.R. No. L-17248)
Case Digest (G.R. No. L-17248)
Facts:
Beatriz Galang v. Hon. Court of Appeals, Maximino Quinit and Rodrigo Quinit, G.R. No. L-17248, January 29, 1962, Supreme Court, Concepcion, J., writing for the Court; Bengzon, C.J., Padilla, Bautista Angelo, Labrador, Reyes, J.B.L., Barrera, Paredes and De Leon, JJ., concurring.Petitioner Beatriz Galang sued Rodrigo Quinit and his father Maximino Quinit in the Court of First Instance (CFI) of Baguio for damages, alleging that Rodrigo had promised to marry her and then abandoned her. The CFI found for Galang and ordered the defendants jointly and severally to pay P275.00 as actual damages, P5,000.00 as moral damages, and P500.00 as attorney’s fees, plus costs.
On appeal, the Court of Appeals reviewed the evidence and acquitted Maximino, reversing the CFI’s liability as to him; it also modified the judgment against Rodrigo by deleting the awards for moral damages and attorney’s fees, leaving only the award for actual damages. The appellate court found Galang’s testimony and proof of the asserted parental conspiracy unworthy of credence.
The underlying facts, as recounted in the record, were contested. Galang claimed she and Rodrigo had been engaged since 1953, lived together as husband and wife at Adolfo Dagawan’s house in Colorado Falls from April 27 to May 9, 1955, and that Rodrigo’s father had promised a dowry and arranged for lodging and wedding plans before withdrawing support and removing Rodrigo. She alleged an attempt to secure a marriage license on May 7 failed for lack of a residence certificate and that Rodrigo left on May 9 and never returned. The Quinit defendants acknowledged an engagement and parental opposition but maintained Rodrigo left the parental home voluntarily (April 26, 1955), went to Colorado Falls to work out plans, repeatedly refused to marry immediately, was later taken home and kept under custody of local officials for a period, and that Maximino never agreed to any scheme to defraud Galang.
Galang brought the case to the Supreme Court by an appeal by certiorari (petition for review). She mainly contested the Court of Appeals’ credibility findings and its refusal to sustain moral damages; she argued moral damages are recoverable for breach of promise to marry. The Supreme Court affirmed the Court of Appeals’ decision.
Issues:
- Were the Court of Appeals’ findings on the credibility of the parties’ evidence reviewable and reversible by the Supreme Court on appeal by certiorari?
- Are moral damages recoverable for breach of promise to marry under Philippine law?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)