A bride declined to appear on her wedding day. Instead, she sent a note to her prospective groom, saying that she needed to be honest to herself by admitting that the institution of marriage was not for her. The bride wrote that she came to this conclusion after contemplating on the tweets of the #LabGuru. She also wrote that to atone for her non-appearance, she would post a glowing recommendation of the prospective groom as a partner on her Facebook, Twitter, Instagram, and TikTok accounts. The couple had previously dated for almost eight years. The whole time, the prospective groom had been loyal and caring. It was the bride who covered all the wedding expenses. Heartbroken and embarrassed, the prospective groom sued the prospective bride for moral damages, alleging that she had breached her promise to marry him. Will the suit prosper? Explain briefly.
Suggested answer only. Not an official answer and not legal advice.
Yes, the suit for moral damages will prosper. Under Article 21 in relation to Article 2219(10) of the Civil Code, any person who willfully causes injury to another in a manner contrary to morals, good customs, or public policy
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Quick check
Under Philippine civil law, is a simple breach of promise to marry an actionable wrong per se?
A simple breach of promise to marry is not an actionable wrong per se under Philippine civil law.
Under Article 21 of the Civil Code, when does a broken promise to marry become actionable for damages?
Article 21 renders a broken promise actionable when accompanied by acts contrary to morals, good customs, or public policy.
In the landmark case of Wassmer v. Velez, why was the defendant held liable for moral damages?
Liability was anchored on the fact that formally setting a wedding and walking out on the wedding day violates good customs.
Under Article 2219(10) of the Civil Code, on what ground may moral damages be recovered in breach of promise cases?
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Why was the prospective groom entitled to recover moral damages in the present case?
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Learn more about these topics
1. Breach of Promise
Under Philippine civil law, a mere breach of promise to marry is not an actionable wrong per se. The law does not compel a person to marry against their free will, nor does it penalize a party simply for changing their mind prior to the wedding ceremony. Consequently, no court can issue a decree for specific performance to force a reluctant party into marriage, nor can damages be recovered solely on the basis of a broken mutual engagement.
2. Contrary to Customs
Under Article 21 of the Civil Code, a person who willfully causes loss or injury to another in a manner contrary to morals, good customs, or public policy is liable for damages. In Wassmer v. Velez, the Supreme Court established that while a breach of promise to marry is non-actionable, formally setting a wedding, completing all preparations, issuing invitations, and abandoning the groom on the wedding day is palpably contrary to good customs, justifying an award of moral damages.
3. Moral Damages Recovery
Under Article 2219, paragraph 10 of the Civil Code, moral damages may be recovered in actions arising from acts or actions referred to in Article 21. Moral damages include physical suffering, mental anguish, fright, serious anxiety, besmirched reputation, wounded feelings, moral shock, and social humiliation. Abandoning a prospective spouse on the wedding day after extensive public preparations inflicts severe emotional distress and social humiliation, legally entitling the aggrieved party to moral damages.