Case Digest (G.R. No. L-18630) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Apolonio Tanjanco vs. Hon. Court of Appeals and Araceli Santos, decided on December 17, 1966 under the 1935 Philippine Constitution, petitioner Apolonio Tanjanco courted respondent Araceli Santos from December 1957 to December 1959. Both were adults; Tanjanco professed undying love and repeatedly promised marriage, leading Santos to consent to carnal relations. Santos became pregnant, resigned her IBM secretarial position to avoid social humiliation, and was unable to support herself and her unborn child. When Tanjanco ceased his visits and refused marriage, Santos filed in the Court of First Instance of Rizal (Civil Case No. Q-4797) a complaint seeking recognition of the unborn child, monthly support, P100,000 moral damages under Article 21 of the Civil Code, and costs. The trial court dismissed the complaint for failure to state a cause of action. On appeal (CA Case No. 27210-R), the Court of Appeals affirmed the dismissal as to recognition and sup Case Digest (G.R. No. L-18630) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Relationship and pregnancy
- From December 1957, petitioner Apolonio Tanjanco (adult male) courted respondent Araceli Santos (adult female), professing undying love and promising marriage.
- In July 1958, in consideration of these promises, Santos consented to carnal relations; they continued intimate intercourse regularly until about July 1959.
- Santos conceived in July 1959; she informed Tanjanco and asked him to fulfill his marriage promise. He ceased visiting her thereafter.
- Due to her pregnancy and fear of social humiliation, Santos resigned as IBM secretary (P230/month), becoming unable to support herself and her unborn child.
- Procedural history
- Santos filed in the Court of First Instance (CFI) of Rizal, Civil Case No. Q-4797, praying for:
- Recognition of the unborn child and support at not less than P430/month;
- Moral and exemplary damages of P100,000;
- Attorney’s fees of P10,000.
- The CFI granted Tanjanco’s motion to dismiss for failure to state a cause of action.
- On appeal, the Court of Appeals (Case No. 27210-R) affirmed the CFI as to recognition and support but held the complaint stated a cause of action for damages under Article 21, Civil Code, and remanded the case.
- Tanjanco elevated the case to the Supreme Court via petition for review on certiorari.
Issues:
- Whether Santos may compel recognition and support of her unborn child before its birth.
- Whether Santos may recover moral and exemplary damages under Article 21 of the Civil Code for breach of promise to marry or seduction.
- Whether breach of promise to marry or consensual adult intercourse constitutes an actionable wrong under Philippine law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)