Case Summary (G.R. No. 214016)
Petitioner
Jhonna Guevarra — argued the P500,000 was a gift; invoked the doctrine that breach of promise to marry is not actionable and relied on natural obligation under Civil Code Article 1423 to contend the money was not recoverable. She sought reversal of earlier rulings ordering return of the money.
Respondent
Jan Banach — sued Guevarra and her parents claiming fraud, unjust enrichment, moral damages, and attorney’s fees under the human-relations provisions of the Civil Code (Articles 20–22). He maintained he intended to marry Guevarra and that the money should be returned under unjust enrichment.
Key Dates and Procedural Posture
- Regional Trial Court (RTC): initially found Guevarra and her parents liable to Banach for actual damages, moral damages, and attorney’s fees.
- Court of Appeals (CA) Decision (promulgated January 29, 2007): ordered return of P500,000 under unjust enrichment but deleted awards of moral damages and attorney’s fees.
- CA Resolution denying reconsideration (July 14, 2014): affirmed return of P500,000; refused moral damages and attorney’s fees.
- Supreme Court: granted petition for review on certiorari and deleted the award of actual damages (P500,000).
Applicable Law and Authorities Relied Upon
- 1987 Constitution (freedom, human dignity, and choice of intimate relations: arts. II, III as cited).
- Civil Code: Articles 20 (liability for willful acts contrary to morals/good customs), 21 (compensation for acts contrary to morals/good customs), 22 (unjust enrichment), and Article 1423 (natural obligations — invoked by petitioner).
- Controlling precedents cited in the decision: Hermosisima v. Court of Appeals (abolition of breach-of-promise cause of action), Estopa v. Piansay, Baksh v. Court of Appeals, Wassmer v. Velez (exception permitting recovery where conduct is palpably and unjustifiably contrary to good customs).
- Procedural reference: Rule 45 petition requirements and Diamond Taxi v. Llamas, Jr. (standard for dispensing with technical defects).
Material Facts Established from the Record
Banach courted Guevarra with visits, gifts, and declarations of intention to marry; he concealed his true identity and marital status; Guevarra confided family difficulties and accepted offers of assistance, including P500,000 sent by Banach for purchase of a lot for their intended conjugal home. Upon discovery of Banach’s deception, Guevarra terminated the relationship. Banach sued to recover the money and for damages.
Procedural Issue: Rule 45 Technical Deficiencies
The respondent challenged the petition’s compliance with Rule 45 (full names, material dates, concise issues). The Supreme Court acknowledged Rule 45’s importance but exercised discretion, relying on available records and the principle favoring full opportunity to litigate merits rather than dismissal on mere technicalities (citing Diamond Taxi). The Court therefore proceeded to decide the case on the merits.
Legal Issue Presented
Whether the order to return the P500,000 given by respondent to petitioner was legally proper — specifically, whether the funds were recoverable under principles of unjust enrichment or other human-relations provisions despite the general rule that breach of promise to marry is not actionable.
Governing Doctrines on Breach of Promise to Marry and Exceptions
- General rule: A mere breach of promise to marry is not actionable in the Philippines, reflecting the omission of such actions in the New Civil Code (Hermosisima; Estopa; Baksh).
- Exception (Wassmer): Recovery may be allowed under Article 21 where conduct is “palpably and unjustifiably contrary to good customs” — e.g., walking out two days before a fully-prepared wedding, causing willful loss or injury contrary to morals/good customs.
- Human-relations provisions presuppose good faith on the part of the party seeking recovery; if the claimant acted in bad faith (fraud, deceit), those provisions do not sustain recovery.
Application of Legal Principles to the Facts
- The Court distinguished Wassmer from the present case: Wassmer’s award was justified because the claimant seeking damages acted in good faith and the defendant’s conduct was flagrantly contrary to good customs. In contrast, Banach’s own conduct was found to be tainted by fraud and deceit (false identity, concealment of existing marriage), which justified Guevarra’s termination of the engagement.
- Because the respondent did not act in good faith, he could not invoke the human-relations provisions (Articles 21/22) to recover the money. Article 22 (unjust enrichment) applies when property was acquired without legal grounds; here, the Court found the P500,000 to be a gift given by Banach to assist Guevarra and her family, and not a transaction unjustly enriching the donee such that restitution was warranted.
- The Court also emphasized public policy and constitutional protections: preserving individual autonomy and dignity in decisions to marry, discouraging judicial intrusion into intimate personal relations, and maintaining policy reasons behind the historical abolition of breach-
Case Syllabus (G.R. No. 214016)
Procedural Posture
- Petition for Review on Certiorari filed in the Supreme Court assails both the Decision and Resolution of the Court of Appeals, which had reversed a Regional Trial Court decision finding petitioner Jhonna Guevarra liable to respondent Jan Banach for damages arising from an alleged breach of promise to marry. (Rollo, pp. 3-6; Decision promulgated January 29, 2007; July 14, 2014 CA Resolution)
- The Court of Appeals (19th Division, Cebu City) in its January 29, 2007 Decision ordered the return of P500,000.00 under the principle of unjust enrichment but deleted awards of moral damages and attorney’s fees. (Rollo, pp. 7-9)
- The Court of Appeals denied Motions for Reconsideration in its July 14, 2014 Resolution, refusing moral damages and attorney’s fees and reiterating reimbursement under unjust enrichment because no marriage materialized. (Rollo, pp. 7-12; pp. 10-11)
- Petitioner Jhonna Guevarra filed a Petition for Review on Certiorari to the Supreme Court contesting the Court of Appeals’ rulings. (Rollo, pp. 3-6)
- The Supreme Court, in a decision penned by Justice Leonen, exercised discretion under Rule 45 to resolve the Petition on the merits and granted the Petition, deleting the award of actual damages worth P500,000.00. (Decision Leonen, J.)
Relevant Factual Background
- Respondent Jan Banach, a German citizen, met petitioner Jhonna Guevarra through Pastor Jun Millamina. (Rollo, p. 22)
- Banach courted Guevarra, visited her almost daily, gave her gifts, and expressed an intention to marry her. (Rollo, p. 23)
- Banach misrepresented his marital status to Guevarra: he told her he was divorced while he was still married to his third wife at the time. (Rollo, pp. 7-8)
- Banach concealed his true identity and used the name “Roger Brawner” in dealings with Guevarra and her family. (Rollo, pp. 7-8)
- Guevarra confided in Banach about family problems, including the risk of eviction from their home. (Rollo, p. 24)
- Banach sent Guevarra P500,000.00 to buy a lot intended for their conjugal home; the two had agreed to marry. (Rollo, pp. 24-25)
- Upon learning of Banach’s lies and deception, Guevarra ended the relationship. (Rollo, p. 8)
- Thereafter, Banach sued Guevarra and her parents for damages before the Regional Trial Court, asserting causes of action based on the human relations provisions of the Civil Code (Articles 20, 21, and 22). (Rollo, pp. 22-31; p. 28)
Claims and Theories of the Parties
- Respondent’s claims:
- Alleged that petitioner repeatedly expressed love and willingness to marry so that he would send her money, and later broke up, constituting fraud or, alternatively, unjust enrichment. (Rollo, p. 8)
- Claimed moral damages for alleged “moral suffering, anguish, anxiety[,] and sleepless nights” and prayed for attorney’s fees as compensation for having to litigate. (Rollo, pp. 28-29)
- Anchored causes of action on Articles 20, 21, and 22 of the Civil Code, and maintained in the Supreme Court pleadings that there was no element of seduction, fraud, or deceit when he sent the money and that his conduct evidenced sincere desire to marry. (Rollo, pp. 28; 14-21; 19)
- Argued that unjust enrichment justified the order to return the P500,000.00. (Rollo, pp. 19-20)
- Raised technical objections that petitioner’s Rule 45 Petition failed to comply with strict pleading requirements (full names, material dates, concise statement of issues), arguing such noncompliance rendered the Petition dismissible. (Rollo, pp. 14-16)
- Petitioner’s claims:
- Maintained that the P500,000.00 was a gift, the return of which is not actionable. (Rollo, p. 9)
- Invoked the doctrine that a breach of promise to marry is not a recognized cause of action in Philippine law and further relied on the law on natural obligations under Article 1423 of the Civil Code to oppose return of the money. (Rollo, pp. 8-9; 4)
- Sought outright reversal of the Regional Trial Court’s Decision, arguing that the Court of Appeals should have applied the breach-of-promise-to-marry doctrine and related defenses (in pari delicto, human relations doctrine on moral seduction, and Article 1423). (Rollo, pp. 4; 31-32)
Lower Courts’ Findings and Reliefs
- Regional Trial Court:
- Found petitioner and her parents liable to respondent for actual damages.
- Also awarded moral damages and attorney’s fees in favor of respondent. (Rollo, p. 7)
- Court of Appeals:
- Ordered the return of P500,000.00 to respondent under the principle of unjust enrichment, because the money was sent for a plan to marry but no marriage occurred. (Rollo, pp. 7-9; 11)
- Deleted the awards of moral damages and attorney’s fees, reasoning respondent’s actions were tainted with fraud and deceit and that he did not have the purest intentions in expressing his desire to marry petitioner. (Rollo, p. 7)
- On reconsideration, the Court of Appeals refused to award moral damages, finding no proof that petitioner acted with fraud or deceit and that the timing of the breakup was understandable upon discovery of respondent’s misrepresentation. It likewise found no basis for attorney’s fees. (Rollo, pp. 10, 11)
Procedural Issue: Rule 45 Pleading Requirements
- Respondent alleged technical deficiencies in the Petition under Rule 45 (missing full names, material dates, concise statement of issues and arg