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G.R. No. L-19671 – 15 SCRA 355 – Civil Law – Torts and Damages – When Liability for Quasi Delict Arises – Unfounded Suit – Alienation of Affection
In February 1948, Pastor Tenchavez and Vicenta Escaño secretly married each other and of course without the knowledge of Escaño’s parents who were of prominent social status and of Spanish descent. The marriage was celebrated by a military chaplain. When Escaño’s parents learned of this, they insisted a church wedding to be held but Escaño withdrew from having a re-celebration because she heard that Tenchavez was having an affair with another woman. Eventually, their relationship went sour; 2 years later, Escaño went to the US where she acquired a decree of absolute divorce and she subsequently became an American citizen. She also married an American.
In 1955, Tenchavez initiated a case for legal separation. He amended the complaint to implead Escaño’s parents for damages as he averred that they dissuaded their daughter to go abroad and caused her to be estranged from him. Tenchavez even accused Escaño’s parents of being racist as they preferred a foreigner for their daughter. Hence he’s asking for damages in the amount of Php1,000,000.00. Escaño’s parents filed a counterclaim in the maount of Php1,000,000.00 as they averred that the damage suit against them is unfounded. The lower court did not grant the legal separation being sought for and at the same time awarded a P45,000.00 worth of counter-claim by the Escaños.
ISSUE: Whether or not damages should be awarded to either party in the case at bar.
On the part of Tenchavez:
His marriage with Escaño was a secret one and the failure of said marriage did not result to public humiliation; that they never lived together and he even consented to annulling the marriage earlier (because Escaño filed for annulment before she left for the US but the same was dismissed due to her non-appearance in court); that he failed to prove that Escaño’s parents dissuaded their daughter to leave Tenchavez. Tenchavez was not able to prove racial or social discrimination. As such his P1,000,000.00 claim cannot be awarded. HOWEVER, by reason of the fact that Escaño left without the knowledge of Tenchavez and being able to acquire a divorce decree; and Tenchavez being unable to remarry, the SC awarded P25,000.00 only by way of moral damages and attorney’s fees to be paid by Escaño and not her parents.
On the part of Escaño’s parents:
It is true that the P1,000,000.00 for damages suit by Tenchavez against the Escaños is unfounded and the same must have wounded their feelings and caused them anxiety, the same could in no way have seriously injured their reputation, or otherwise prejudiced them, lawsuits having become a common occurrence in present society. What is important, and has been correctly established in the decision of the lower court, is that they were not guilty of any improper conduct in the whole deplorable affair. The SC reduced the damages awarded from P45,000.00 to P5,000.00 only.