Case Digest (G.R. No. 214016) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 214016, Jhonna Guevarra et al. v. Jan Banach, decided on November 24, 2021 under the 1987 Constitution, the respondent, Jan Banach, a German citizen, met petitioner Jhonna Guevarra through Pastor Jun Millamina. Banach courted Guevarra by daily visits, gifts, and declarations of intent to marry, concealing his ongoing marriage to a third wife and assuming the alias “Roger Brawner.” Guevarra, burdened by her family’s risk of eviction, confided in Banach and accepted his proposal when he sent ₱500,000.00 to purchase a lot for their envisioned conjugal home. Upon discovering Banach’s deceit regarding his marital status and identity, she ended the relationship. Thereafter, Banach sued Guevarra and her parents before the Regional Trial Court (RTC) for damages under Civil Code Articles 20, 21, and 22, alleging fraud or unjust enrichment, claiming moral damages for anxiety and sleepless nights, and praying for attorney’s fees. The RTC found them liable for actual damages, mo Case Digest (G.R. No. 214016) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Courtship and promise to marry
- German citizen Jan Banach met Jhonna Guevarra through Pastor Jun Millamina, courted her with daily visits, gifts, and expressed his intention to marry.
- Banach concealed his true identity (using the name “Roger Brawner”) and marital status (he was still married), representing himself as a divorced man.
- Agreement and financial assistance
- Trusting Banach, Guevarra confided in him about her family’s risk of eviction and agreed to marry him.
- Banach sent Guevarra ₱500,000 to purchase a lot for their conjugal home.
- Breakup and trial court proceedings
- Upon discovering Banach’s deception, Guevarra ended the engagement.
- Banach sued Guevarra and her parents under Civil Code Articles 20–22 for fraud, unjust enrichment, moral damages, and attorney’s fees; the Regional Trial Court (RTC) found them liable and awarded actual and moral damages as well as attorney’s fees.
- Court of Appeals decision and resolution
- The Court of Appeals (CA) upheld the return of ₱500,000 under unjust enrichment but deleted awards for moral damages and attorney’s fees, finding Banach’s claim tainted by his own fraud.
- Motions for reconsideration were denied; Guevarra then filed a Petition for Review on Certiorari with the Supreme Court, arguing the funds were an inalienable gift and invoking the doctrine that breach of promise to marry is not actionable.
- Respondent’s defenses before the Supreme Court
- Banach challenged the Petition’s technical compliance with Rule 45 (omission of full names, material dates, and concise issues).
- Substantively, he maintained no bad faith—his intent to marry was genuine, there was no moral seduction, and the claim rested on unjust enrichment, not breach of promise.
Issues:
- Procedural compliance
- Did the Petition for Review on Certiorari comply with Rule 45 requirements for Supreme Court review?
- Return of ₱500,000
- Is there a legal basis under the Civil Code’s human relations provisions or unjust enrichment principles to order Guevarra to return the ₱500,000?
- Actionability of breach of promise to marry
- Does Philippine law recognize a cause of action for breach of promise to marry?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)