Case Digest (G.R. No. L-20089) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Beatriz P. Wassmer v. Francisco X. Velez (120 Phil. 1440, Dec. 26, 1964), the parties agreed to marry on September 4, 1954. Two days before the wedding, Velez left a note postponing it due to his mother’s opposition, followed by a telegram assuring his return. He then disappeared and never communicated further. Wassmer filed suit for damages; Velez made no appearance and was declared in default. On April 29, 1955, the lower court, based on evidence taken by the clerk of court as commissioner, awarded P2,000.00 as actual damages, P25,000.00 as moral and exemplary damages, P2,500.00 attorney’s fees, and costs. On June 21, 1955, Velez filed a petition for relief from judgment and motion for new trial, alleging “excusable negligence” in failing to answer because he believed an amicable settlement was forthcoming. The court attempted settlement conferences on August 23, 1955 and July 13, 1956; Velez failed to appear personally, and his counsel later reported no possibility of agre Case Digest (G.R. No. L-20089) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Preliminary Engagement and Breach
- Francisco X. Velez and Beatriz P. Wassmer promised marriage set for September 4, 1954; two days prior Velez left a note postponing the wedding due to his mother’s opposition and boarded a plane for Mindanao; on September 3 he telegrammed a promise to return but never did.
- Plaintiff prepared extensively: obtained a marriage license (Exhs. A, A-1), printed and distributed invitations (Exh. C), purchased bridal trousseau, party dresses, a matrimonial bed and received bridal gifts (Exh. E).
- Procedural History
- In April 1955, plaintiff sued for damages; defendant defaulted by filing no answer; evidence was taken before the clerk-commissioner; judgment awarded P2,000 actual, P25,000 moral and exemplary damages, P2,500 attorney’s fees, and costs.
- On June 21, 1955, defendant filed a petition for relief and new trial alleging excusable negligence with an affidavit of merit; the trial court granted repeated chances for settlement, denied relief on July 20, 1956; defendant appealed.
Issues:
- Setting Aside Default
- Did the petition for relief comply with Rule 38’s affidavit-of-merit requirement?
- Was the procedure of taking evidence before the clerk valid without defendant’s consent?
- Actionability of Breach
- Is breach of promise to marry an actionable wrong under the Civil Code?
- Does Article 21 provide a cause of action for injury to morals and public policy?
- Quantum of Damages
- Were the moral and exemplary damages of P25,000 excessive?
- What is the reasonable amount for moral and exemplary damages under the circumstances?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)