Batarra v. Marcos
REITERATIONFacts
The Antecedents: The plaintiff, Fausta Batarra, filed a complaint against the defendant, Francisco Marcos, seeking damages for breach of promise of marriage. The plaintiff alleged that the defendant induced her to engage in sexual relations with him based on his promise to marry her. Procedural History: The court below rendered a judgment in favor of the plaintiff, awarding her 500 pesos in damages. The defendant excepted to this judgment and appealed the case to the Supreme Court. The Appeal: The defendant appealed the decision of the lower court, arguing that the judgment was not supported by law or evidence. The Supreme Court reviewed the case to determine the legal basis for the plaintiff's claim.
Issue(s)
Whether the defendant is liable for damages for breach of promise to marry, considering the sexual relations between the parties. Whether the act constituted seduction under the Penal Code. Whether the plaintiff can recover damages under Article 1902 of the Civil Code.
Ruling
The Supreme Court reversed the judgment of the lower court, acquitting the defendant of the complaint. No costs were awarded to either party in the Supreme Court.
Ratio Decidendi
On Issue 1: The Supreme Court held that the defendant is not liable for damages for breach of promise to marry under the circumstances presented. The Court reasoned that if the carnal intercourse between the parties was a crime or misdemeanor, it was common to both parties, and Article 1305 of the Civil Code prevents recovery. Similarly, if the act did not constitute a crime or misdemeanor, it was an immoral act, and under Article 1306 of the same code, no recovery can be had by one against the other because the fault lay with both parties. The Court emphasized that the plaintiff voluntarily participated in the act, invoking the principle scienti et volenti nula fit injuria neque dolus. On Issue 2: The Court found that the facts did not establish the commission of the crime of seduction as defined by Article 443 of the Penal Code. This was because it did not appear that the plaintiff was under 23 years of age, a requirement for the crime of seduction under that provision. Consequently, the judgment could not be based upon Article 449 of the Penal Code, which provides for indemnification in cases of rape, seduction, and abduction. On Issue 3: The Court ruled that the plaintiff could not recover damages under Article 1902 of the Civil Code. This article provides that a person who, by an act or omission causing damage to another with fault or negligence, shall be obliged to repair the damage. However, the Court found that the plaintiff voluntarily participated in the act, which precluded her from claiming damages under this provision, as the principle of volenti non fit injuria (to a willing person, injury is not done) applied.
Main Doctrine
The Supreme Court held that a party cannot recover damages for breach of promise to marry if the carnal connection, which served as the consideration for the promise, was an immoral act in which both parties voluntarily participated. The Court invoked Articles 1305 and 1306 of the Civil Code, stating that when the nullity arises from the illegality of the cause or object of the contract, and both parties are equally guilty, no claim can be set up against the other. Additionally, under Article 1902, voluntary participation in the act bars recovery.