Guevarra, et al. v.

Banach
G.R. No. 214016
Ponente LEONEN, J
Nov 24, 2021
In the case of Guevarra v. Banach, the Supreme Court ruled in favor of Jhonna Guevarra, stating
that a breach of promise to marry is not an actionable wrong as long as it does not contradict
good customs, and the party seeking damages must have acted in good faith.
Facts:
 Jan Banach, a German citizen, met Jhonna Guevarra through Pastor Jun Millamina.
 Banach courted Guevarra, visiting her almost every day, giving her gifts, and expressing
his intention to marry her.
 Banach did not disclose that he was still married to his third wife and presented himself
as a divorced man named Roger Brawner.
 Guevarra agreed to marry Banach and he sent her P500,000.00 to buy a lot for their
conjugal home.
 Guevarra discovered Banach's lies and deception and broke up with him.
 Banach sued Guevarra and her parents for damages, alleging fraud and unjust
enrichment.
Issue:
 Is the order to return the P500,000.00 given by Banach to Guevarra proper?
Ruling:
 The Supreme Court ruled in favor of Guevarra and deleted the award of damages to
Banach.
Ratio:
 A mere breach of promise to marry is not an actionable wrong, as long as it does not
contradict good customs.
 The party seeking damages must have acted in good faith.
 Guevarra called off the engagement after discovering Banach's lies and deception.
 Banach's actions were tainted with fraud and deceit, and he did not have the purest
intentions in marrying Guevarra.
 Guevarra cannot be compelled to return the P500,000.00 given to her as it was a gift.
 The Court reiterated the doctrine that a breach of promise to marry is not an actionable
wrong, unless it palpably and unjustifiably contradicts good customs.
 The party seeking damages must have acted in good faith.
 Banach's actions were fraudulent and deceitful, justifying Guevarra's decision to call off
the engagement.
 The Court recognized the fundamental right to marry and the importance of individual
autonomy in choosing a life partner.
 Courts should not meddle in personal affairs and discourage litigation in matters of
broken promises in intimate relationships.
Case Background and Parties Involved
 The case of Guevarra v. Banach involved Jhonna Guevarra (Guevarra) and Jan Banach
(Banach).
 Banach, a German citizen, courted Guevarra and promised to marry her, even sending
her money for their conjugal home.
 Guevarra later discovered that Banach had lied about his marital status and true
identity, leading to their breakup.
Breach of Promise to Marry as an Actionable Wrong
 The Philippine court ruled that a breach of promise to marry is not an actionable wrong
if it does not contradict good customs and the party seeking damages acted in good
faith.
 The Regional Trial Court found Guevarra liable for damages, but the Court of Appeals
reversed the decision, ruling that Banach's actions were tainted with fraud and deceit.
Petition for Review on Certiorari
 Guevarra filed a Petition for Review on Certiorari, arguing that the money given to her
was a gift and not actionable.
 The Supreme Court granted the petition, stating that a breach of promise to marry is not
actionable unless there is fraud or deceit involved.
Lack of Good Faith and Fraudulent Actions
 The Court emphasized that Banach did not act in good faith, as he lied about his marital
status and true identity.
 Banach's actions were deemed tainted with fraud and deceit, which further supported
the ruling that a breach of promise to marry is only actionable when fraud or deceit is
present.
Money Given as a Gift
 The Supreme Court considered the money given to Guevarra as a gift, rather than a
form of damages.
 This further supported the ruling that Banach cannot claim damages, as the money was
not given with the expectation of compensation for the breach of promise to marry.
Fundamental Right to Marry and Autonomy in Choosing a Spouse
 The court emphasized that the right to marry is a fundamental human right.
 Individuals should have the autonomy to choose whom to marry without fear of legal
retribution.
 The court discouraged litigation for broken promises in intimate relationships.
Deletion of Damages Award
 As a result of the Supreme Court's ruling, the award of damages to Banach was deleted.
 This decision was based on the lack of good faith on Banach's part and the consideration
of the money given as a gift.
Conclusion
 The case of Guevarra v. Banach established that a breach of promise to marry is not an
actionable wrong unless fraud or deceit is involved.