Francisco and Beatriz were in love. After promising to marry each other, they set September 4, 1954 as their wedding day. Preparations were made. Invitations were printed and distributed. Wedding apparel was purchased. Bridal showers were held. Gifts were received. Even the matrimonial bed had already been bought. Everything appeared ready for the big day.
Then, two days before the wedding, Francisco left a note. It read:
“Will have to postpone wedding. My mother opposes it.”
The note added that he was leaving that day and asked Beatriz not to ask too many people about the reason because it might create a scandal. The next day, however, Francisco sent a telegram reassuring his bride-to-be that nothing had changed and that he would return soon.
He never did. He was never heard from again.
Humiliated and devastated, Beatriz filed a case for damages. Francisco argued that there is no cause of action for breach of promise to marry.
Was he correct?
Partly—but not entirely.
The Supreme Court agreed that under Philippine law, a mere breach of promise to marry is not, by itself, an actionable wrong. A person cannot ordinarily be sued simply because he changes his mind and decides not to marry.
But according to the Court, this was not an ordinary case.
The Court emphasized that Francisco and Beatriz had already gone far beyond a private promise of marriage. A marriage license had been obtained. Invitations had been distributed. Wedding preparations had been completed. Family members, relatives, friends, and acquaintances had been informed of the impending ceremony. Then, only two days before the wedding, Francisco abruptly disappeared.
The Supreme Court held that such conduct was not merely a breach of promise to marry. It was a willful act that caused injury in a manner contrary to morals, good customs, and public policy.
For that reason, the Court applied Article 21 of the Civil Code, which provides that any person who willfully causes loss or injury to another in a manner contrary to morals, good customs, or public policy must compensate the injured party.
According to the Court, to publicly prepare for a wedding, encourage extensive preparations, allow the bride and her family to incur expenses and endure public exposure, and then abandon the marriage at the last moment without justification was plainly contrary to good customs.
The Court therefore ruled that Francisco was liable for damages.
It likewise upheld the award of moral damages. The Court recognized the embarrassment, humiliation, wounded feelings, and emotional suffering that Beatriz experienced after being abandoned on the eve of her wedding.
The Court also sustained the award of exemplary damages, finding that Francisco had acted in a wanton, reckless, and oppressive manner.
Accordingly, the Supreme Court held Francisco liable for damages and affirmed the judgment in favor of Beatriz, subject only to a reduction in the amount awarded.