Beyond heartbreak: When a canceled wedding becomes a crime

MANILA, Philippines – What started as a quiet love story between a police officer and a public school teacher became a Supreme Court decision that redefines where and how liability attaches for a broken promise to marry.

Sometime in 2019, the police officer and the teacher entered into a romantic relationship. On April, 2020, the teacher discovered she was pregnant. Her boyfriend, the police officer, welcomed the news.

READ: SC rules in favor of woman who called off wedding

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Both families welcomed the latest development and agreed to a quiet, future-bound Holy matrimony. They scheduled a visit to the Local Civil Registrar on June 1, 2020, to apply for a marriage license.

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However, on that date, the police officers’ colleagues informed both families that he could not attend because he was called to a police operation.

“This came as a shock to AAA (teacher), as XXX (police officer) had previously assured her he would seek permission from his superiors to be relieved of duty for the wedding preparations,” the Supreme Court said.

“AAA felt utterly humiliated and ashamed, having already informed her family and friends of the impending marriage license application,” it added.

When XXX returned, they managed to submit their marriage license application. However, he secretly returned to the municipal hall that very same day to retrieve his documents and scrap the wedding entirely. He walked away, claiming family disapproval and cold feet, leaving behind a woman carrying his child into a storm of public ridicule and overwhelming isolation.

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AAA filed a complaint for violating Republic Act 9262 or the Anti-Violence Against Women and their Children Act of 2004. In court, social worker and medical expert testified to the victim’s collapse. Her tests revealed that she suffered from restless nights, severe depression, and suicidal thoughts. 

Meanwhile, XXX argued that her family had set the date for the marriage application. He admitted that he never expressly agreed to marry her despite the pregnancy, citing his own health issues, which included seizure attacks and his grandfather’s illness. Still, he maintained he never evaded his obligation to her and their unborn child.

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He said he agreed to submit their application only because AAA was becoming emotional, and that he withdrew the documents for their marriage license application so he could use them for his “License to Own and Possess Firearms” application. He said he was shocked to learn an arrest warrant had been issued against him.

The Regional Trial Court found him guilty of emotional abuse under the VAWC Law and he was sentenced to up to 10 years and one day imprisonment and P100,000 fine and undergo mandatory psychological counselling in any government institution.

The court required him to report to court once he completed the counselling.

The Court of Appeals affirmed the lower court’s ruling, but instead of a P100,000 fine, it also required XXX to pay P150,000 moral and exemplary damages. 

In affirming the lower court and the Court of Appeals’ ruling, the Supreme Court’s First Division, in its July 29 decision, said that while a simple breach of promise to marry is not an actionable wrong, the acts that inflicted severe emotional and mental suffering fall squarely under psychological violence.

“Where an act – even one involving marriage applications – is used as a tool to inflict psychological trauma on a woman in a dating or sexual relationship, the law must be interpreted to hold the offender liable,” the Supreme Court said in a ruling written by Associate Justice Ramon Paul Hernando.

The Supreme Court emphasized that while breaking off a relationship is not in itself a crime, using sudden, public abandonment as a tool of humiliation against a vulnerable, pregnant partner “transcends simple heartbreak and enters the realm of psychological violence.”

The Supreme Court modified the imprisonment to only up to nine years and one day, but the fine and damages were affirmed.

The monetary award of P150,000 shall earn legal interest of six percent per annum from the date of finality of the decision until fully paid.

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Chief Justice Alexander Gesmundo and Associate Justices Rodil Zalameda, Ricardo Rosario and Jose Midas Marquez concurred in the decision. /jpv