Case Summary (G.R. No. 214016)
Petitioner
Jhonna Guevarra and her parents, who were ordered by the Court of Appeals to return P500,000 received from Banach.
Respondent
Jan Banach, who sought reimbursement and damages for what he characterized as unjust enrichment and moral injury following the dissolution of the engagement.
Key Dates
- Court of Appeals Decision: January 29, 2007
- Court of Appeals Resolution (denying reconsideration): July 14, 2014
- Supreme Court Decision on Review: November 24, 2021
Applicable Law
- 1987 Philippine Constitution (freedom of choice, human dignity)
- Civil Code of the Philippines (Articles 21 on human relations, 22 on unjust enrichment, 1423 on natural obligations)
- Family Code of the Philippines (Article 1 on the nature of marriage)
Procedural History
Banach filed for damages and reimbursement before the Regional Trial Court (RTC) after Guevarra terminated their engagement upon discovering his misrepresentations. The RTC awarded actual and moral damages plus attorney’s fees. The Court of Appeals affirmed the reimbursement under unjust enrichment but deleted moral damages and attorney’s fees. Guevarra petitioned for certiorari, invoking doctrines on natural obligations and breach of promise to marry; Banach defended the unjust enrichment award.
Facts and Background
Banach courted Guevarra, lavished gifts, professed intent to marry, and advanced P500,000 to purchase a lot for their future home. Guevarra later learned that Banach was still married and had concealed his identity. She broke off the engagement and retained the funds.
Claims and Counterclaims
- Respondent’s Cause of Action: Unjust enrichment (Civil Code Art. 22), moral damages, attorney’s fees, based on Articles 20–22 (human relations).
- Petitioner’s Defense: The P500,000 was an unconditional gift or, if natural obligation, its return was not actionable (Art. 1423). She further invoked the non-recognition of breach-of-promise suits.
Lower Courts’ Findings
- RTC: Liability for actual and moral damages, plus attorney’s fees.
- Court of Appeals: Reimbursement of P500,000 under unjust enrichment; rejected moral damages and attorney’s fees due to respondent’s bad faith.
Arguments on Review
- Petitioner: Reimbursement barred by the doctrine on non-actionability of breach of promise to marry, by in pari delicto, and as a natural obligation.
- Respondent: Technical defects in the petition; claim of sincere intent to marry and absence of fraud; anchoring remedy on unjust enrichment, not breach of promise.
Main Issue and Standard
Whether the order to return P500,000 is legally supportable under the Civil Code and consistent with constitutional protections of individual autonomy in marital choice.
Breach of Promise to Marry Doctrine
Under Hermosisima v. CA and subsequent decisions, mere breach of promise to marry is not actionable. Exceptions under Wassmer v. Velez allow damages only when cancellation flagrantly violates good customs (e.g., last-minute wedding abandonment).
Human Relations Provisions and Good Faith Requirement
Article 21 permits damages for acts “contrary to morals, good customs or public policy” only if the claimant acted in good faith. Article 22 mandates return of benefits acquired without legal ground, but unjust enrichment is unavailable to one who has acted in bad faith.
Application to This Case
Respondent’s own fraud and deceit—misrepresentation of marital status and identity—amounted to bad faith, justifying Guevarra’s termination of the
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Facts
- Jan Banach, a German citizen, met Jhonna Guevarra through Pastor Jun Millamina.
- Banach courted Guevarra daily, presented gifts, and declared his intention to marry her.
- He concealed his marital status—still married to his third wife—and falsely represented himself as a divorced man named “Roger Brawner.”
- Guevarra confided her family’s financial difficulties, including possible eviction, to Banach.
- Relying on his promises, Guevarra agreed to marry and received ₱500,000 from Banach to purchase a lot for their planned conjugal home.
Discovery and Breakup
- Guevarra learned of Banach’s lies and deception regarding his identity and marital status.
- Upon discovering the truth, she terminated the engagement and ceased communication with Banach.
Regional Trial Court Proceedings
- Banach filed suit against Guevarra and her parents for damages, invoking Articles 20, 21, and 22 of the Civil Code (human relations and unjust enrichment).
- He alleged that Guevarra’s expressions of love and intention to marry were fraudulent inducements for him to send money.
- He claimed actual damages (₱500,000), moral damages for “anguish, anxiety, and sleepless nights,” and attorney’s fees.
- Guevarra maintained that the ₱500,000 was a gift, not subject to return.
- The Regional Trial Court found Guevarra and her parents liable: it ordered reimbursement of ₱500,000, awarded moral damages, and granted attorney’s fees.
Court of Appeals Decision and Resolution
- January 29, 2007 Decision:
- Ordered return of ₱500,000 under the principle of unjust enrichment.
- Deleted awards of moral damages and attorney’s fees, citing Banach’s own fraud and impure intentions.
- July 14, 2014 Resolution:
- Denied motions for recons