Case Summary (G.R. No. 101749)
Factual Background and Material Dates
On the afternoon of September 8, 1973, Conrado Bunag, Jr. allegedly abducted Zenaida Cirilo in Pasay City, took her to a motel where he raped her, and later brought her to his grandmother's house in Pamplona, Las Piñas, where they lived together as husband and wife until September 29, 1973. Applications for a marriage license were filed on September 10, 1973, but petitioner later withdrew his application on October 1, 1973. Cirilo testified to the abduction and rape, which were corroborated by her uncle. The petitioner and his father denied these allegations, claiming the circumstances amounted to a consensual elopement based on mutual agreement to marry.
Trial Court’s Findings and Civil Suit for Damages
The Regional Trial Court, Branch XIX, Bacoor, Cavite, found Bunag, Jr. liable for damages due to forcible abduction, rape, and breach of promise to marry. The court ordered damages including moral, exemplary, temperate damages, and attorney’s fees totaling P130,000.00. The father, Conrado Bunag, Sr., was absolved from liability. Cirilo appealed to hold the father civilly liable, and the Bunags appealed the trial court’s findings on abduction, rape, promise to marry, and award of damages.
Court of Appeals’ Ruling
The Court of Appeals affirmed the trial court’s decision, emphasizing that the evidence supported the finding of forcible abduction and rape, not a mere elopement and consensual agreement to marry. It upheld the moral and exemplary damages awarded, recognizing the grave violation of Cirilo’s rights and dignity.
Petitioner's Arguments on Appeal
Petitioner argued that the trial and appellate courts failed to consider vital exhibits and testimonies essential to his defense, misapprehended facts related to the agreement to marry, and improperly applied the law by treating the incident as forcible abduction with rape rather than a simple elopement. He also contended that the damages awarded were excessive and that the dismissal of the criminal complaint for abduction with rape precluded civil liability.
Jurisprudential Principles on Review of Factual Findings
The Supreme Court reiterated the well-established rule that findings of fact by the Court of Appeals are generally conclusive and will not be disturbed unless shown to be unsupported by the record or gravely erroneous. The Court is confined to reviewing errors of law and does not re-evaluate evidence or witness credibility.
Legal Analysis on Breach of Promise to Marry and Damages
The Court acknowledged that under Philippine law, breach of promise to marry is generally not actionable except where expenses were incurred based on such promise. However, the petitioner's acts of abduction and rape and subsequent false promise to marry, intended to evade criminal responsibility, constituted conduct contrary to morals, good customs, and public policy, justifying the award of moral and exemplary damages pursuant to Articles 21 and 2219 of the Civil Code.
Distinction Between Criminal and Civil Liabilities
The Court clarified that dismissal of the criminal complaint dur
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Background and Procedural History
- This case arises from a Petition for Review appealing the May 17, 1991 decision of the Court of Appeals (CA) in CA-G.R. CV No. 07054, which affirmed the Regional Trial Court’s (RTC) decision in Civil Case No. N-2028 at Branch XI, Bacoor, Cavite.
- The RTC ruled in favor of Zenaida B. Cirilo, ordering Conrado Bunag, Jr. to pay damages for forcible abduction, rape, and breach of promise to marry.
- The CA denied petitioner Bunag Jr.'s motion for reconsideration, prompting the elevated review by the Supreme Court.
- Petitioner seeks reversal arguing misapprehension of facts, improper application of law concerning forcible abduction versus elopement, and excessive damages awarded.
Factual Background
- On September 8, 1973, petitioner Conrado Bunag, Jr. allegedly abducted and raped private respondent Zenaida B. Cirilo at a motel after they were together at a hospital vicinity in Pasay City.
- Petitioner then brought private respondent to his grandmother’s house in Pamplona, Las Piñas, Metro Manila, where they cohabited as husband and wife for 21 days.
- Both parties filed applications for a marriage license on September 10, 1973; however, petitioner later withdrew his application after leaving private respondent on September 29, 1973.
- Private respondent testified that she was forcibly taken, threatened, and sexually assaulted by petitioner and an unidentified male companion.
- Petitioner and his father were involved in assurances and promises to marry before petitioner abruptly abandoned private respondent.
- Petitioner and private respondent claimed their relationship was an elopement plan, evidenced by hotel registrations and testimonies of friends and acquaintances.
Contention of Parties
- Private respondent asserts forcible abduction and rape based on her account, describing physical violence and threats, loss of virginity, and coerced promise to marry.
- Petitioner denies forcible abduction and rape, maintaining the relationship was a consensual elopement due to paternal opposition. Petitioner claims withdrawal of marriage plans due to disagreements and threats.
- Petitioner’s father, Conrado Bunag, Sr., denies involvement or agreement to the marriage and was absolved of liability by the RTC.
- Private respondent sued for damages for breach of promise to marry and the consequences of the alleged abduction and rape.
Issues Raised for Review
- Whether the RTC and CA erred in finding petitioner guilty of forcible abduction and rape as opposed to consensual elopement and agreement to marry.
- Whether the award of moral, exemplary, temperate damages, attorney’s fees, and costs of