At the turn of the year, news about a supposedly missing bride-to-be surfaced and filled the internet and our social networking sites. Purportedly, this bride-to-be went missing four (4) days before its scheduled wedding on December 14, 2025 to her boyfriend of ten (10) years. According to the groom, his last communication with her prior the latter’s disappearance was on December 10, 2025 when she messaged him that she will go to the mall to buy shoes for their wedding. After that, the said bride-to-be never returned home and left her cellphone.
Worried, the groom reported the matter to the authorities which immediately started the search. On December 29, or nineteen (19) days from her disappearance, the bride-to-be was found and located, safe, and unscathed, somewhere in Pangasinan.
Having this storyline, netizens assumed that this is a case of run-away bride. (This column does not in any assume or conclude that such incident indeed pertains to a run-away bride scenario) With this, legal discussion and querries arose as to the liability of a person who breached her or his promise to marry another. Thus, let’s tackle and dwell into the several Supreme Court pronouncements regarding this matter.
In civil law, it is well-settled that a mere breach of a promise to marry is not an actionable wrong as long as it is not of such extent as would palpably and unjustifiably contradict good customs. In any case, the party seeking to recover damages must have acted in good faith. This is the jurisprudential teachings in the landmark case of Wassmer vs Velez (G.R. No. L-20089, December 26, 1964) which was reiterated in Guevarra vs Banach (G.R. No. 214016, November 24, 2021)
In Guevarra vs Banach, the Court enunciated that: Marriage is a social institution that creates a permanent bond between individuals, and the law grant their rights and obligations unique to married couples. The choice of whether to marry and necessarily, whom to marry-is a personal decision that a person make for themselves. This individual choice must be made, as much as possible, completely free from any external pressures. After all, marriage can and will change a person’s life.
Thus, choosing a person to marry is intimately connected to a person’s autonomy. Any State interest in the institution of marriage must not lead to an unjustified intrusion into one’s individual autonomy and human dignity. It must only be done when public interest is imperiled. It is not within the courts’ competence to reach too far into intimate relations. Courts, through litigation, should not dictate on or even pressure a person into accepting a life of marriage with a person they reject. Courts must, as much as possible, refrain from meddling in these personal affairs.[1]
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An individual has the autonomy to choose whom to marry, or whether to marry at all. They must be free to make that choice without any fear of legal retribution or liability. The decision on whether to marry is one that should be freely chosen, without the pressures of a possible civil suit should a person realize that their intended partner is not right for them. We recognize instances when the breach of one’s commitment in an intimate relationship is a consequence of their realization that marriage may not be the wisest path they could take given their circumstance. For this reason, litigation to the sorrows caused by a broken heart and a broken promise must be discouraged.[2]
Be that as it may, however, the High Court, in Wassmer vs Velez, had held that run-away groom or bride is still liable for damages if the other party had already went through the necessary preparation and publicity, and spent reasonable amount of money for invitations, dresses, bridal showers, wedding accessories and etcetera. As declared therein, “surely this is not a case of mere breach to marry. As stated, mere breach to marry is not an actionable wrong. But to formally set a wedding and go through all the above-described preparation and publicity only to walk out of it when the matrimony is about to be solemnized, is quite different. This is palpably and unjustifiably contrary to good customs for which defendant must be held answerable in damages in accordance with Article 21 of the Civil Code.
[1] Idem
[2] Idem