Banzuela v. Tabiliran
REITERATIONFacts
The Antecedents: Teresita Banzuela filed a verified complaint on June 4, 1965, against Atty. Jose C. Tabiliran, Jr., charging him with failure to fulfill his promise to marry her. Miss Banzuela, an eighteen-year-old third-year college student, alleged that she surrendered her virtue based on the respondent's promise to marry her and that she was pregnant. Procedural History: The respondent submitted an answer to the complaint in compliance with the Court's resolution of July 19, 1965. However, the answer was not attached to the record for unknown reasons. Subsequently, on September 9, 1977, the respondent filed a motion to dismiss, asserting that he and the complainant were married on March 7, 1966, at the Saint Francis Xavier Church in Katipunan, Zamboanga del Norte. He attached a certified copy of the marriage certificate to his motion and prayed for the dismissal of the case. The Petition: This case originated from a complaint filed by Teresita Banzuela against Atty. Jose C. Tabiliran, Jr. before the Supreme Court, charging him with failure to fulfill his promise to marry her, which allegedly led to her seduction and pregnancy. The respondent, in his motion to dismiss, presented a marriage certificate as proof that he and the complainant had subsequently married, thereby rendering the original complaint moot and academic. The core of the respondent's argument was that the subsequent marriage extinguished the cause of action.
Issue(s)
Whether the complaint for failure to fulfill a promise to marry should be dismissed considering the subsequent marriage of the parties.
Ruling
The Supreme Court, in a Resolution, ordered that the case be dropped and considered closed.
Ratio Decidendi
On Whether the complaint for failure to fulfill a promise to marry should be dismissed considering the subsequent marriage of the parties: The Court considered the motion to dismiss filed by the respondent, Atty. Jose C. Tabiliran, Jr., which was dated September 9, 1977. In this motion, the respondent alleged that he and the complainant, Teresita Banzuela, were married on March 7, 1966, at the Saint Francis Xavier Church located in Katipunan, Zamboanga del Norte. To substantiate this claim, the respondent enclosed a certified copy of the marriage certificate. The subsequent marriage of the parties effectively rendered the original complaint for failure to fulfill a promise to marry moot and academic. The basis of the complaint was the alleged breach of promise to marry, which, by virtue of their subsequent union, was no longer a valid cause of action. Therefore, the Court found it proper to dismiss the case. The dispositive portion of the Resolution clearly states that the case is dropped and considered closed, reflecting the Court's acknowledgment of the supervening event that extinguished the dispute.
Main Doctrine
The Supreme Court, in a Resolution, dismissed a complaint for failure to fulfill a promise to marry after the respondent presented a marriage certificate showing that he and the complainant had subsequently married. This subsequent marriage rendered the case moot and academic, as the original cause of action was extinguished by the union of the parties.