G.R. No. 214016. November 24, 2021
JHONNA GUEVARRA ET AL., PETITIONER, VS. JAN BANACH, RESPONDENT.

FACTS

Jan Banach, a German citizen, courted Jhonna Guevarra, representing himself as a divorced man named “Roger Brawner,” and promised to marry her. He concealed that he was still married to his third wife. Guevarra, confiding her family problems including potential eviction, accepted his proposal. Banach sent Guevarra P500,000.00 to buy a lot for their conjugal home. When Guevarra discovered Banach’s deception regarding his identity and marital status, she broke off the relationship. Banach filed a complaint for damages against Guevarra and her parents before the Regional Trial Court, alleging fraud and unjust enrichment under Articles 20, 21, and 22 of the Civil Code, claiming the money was sent due to her repeated expressions of love and willingness to marry. Guevarra argued the money was a gift. The Regional Trial Court found Guevarra and her parents liable for actual damages, moral damages, and attorney’s fees. The Court of Appeals, in its Decision, ordered the return of the P500,000.00 based on unjust enrichment but deleted the awards for moral damages and attorney’s fees, noting Banach’s own fraud and deceit. Both parties sought reconsideration. The Court of Appeals denied the motions, reiterating the order to return the money but refusing to award moral damages as Guevarra’s breakup was a reasonable reaction to discovering Banach’s misrepresentations. Guevarra filed a Petition for Review on Certiorari before the Supreme Court.

ISSUE

Whether or not the order for Jhonna Guevarra to return the P500,000.00 to Jan Banach is proper.

RULING

No. The Supreme Court granted the Petition. The Court held that a mere breach of a promise to marry is not an actionable wrong. While damages may be recoverable under Article 21 of the Civil Code if the act is palpably and unjustifiably contrary to good customs (as in Wassmer v. Velez where a wedding was canceled two days prior after extensive preparations), such is not the case here. The Court found that Banach was not in good faith; he actively deceived Guevarra about his identity and marital status. His claim for unjust enrichment under Article 22 of the Civil Code must fail because the provision requires the acquisition to be “without just or legal ground.” The money was given in the context of a promise to marry founded on Banach’s own fraudulent representations. To allow recovery would be to permit him to profit from his deceit. The Court emphasized that parties seeking relief under the human relations provisions of the Civil Code must come with clean hands. Since Banach’s conduct was characterized by fraud, he is not entitled to the return of the money. The procedural deficiencies in Guevarra’s Petition were overlooked by the Court in the interest of substantive justice.