Breaking promise to marry may ultimately constitute psychological violence and be punishable with jail time: SC

The Supreme Court has found a man guilty of inflicting psychological violence against a woman he had originally agreed to marry but then intentionally withdrew their marriage license application later on.

In a decision promulgated on July 29 and released on Aug. 17, the SC First Division upheld the ruling of the Regional Trial Court and found the accused "guilty beyond reasonable doubt of psychological violence". 

The case

According to the petitioner, a public school teacher whose name was redacted in the document and assigned the pseudonym AAA, she and her now former fiancé, XXX, a police officer, began a relationship in 2019 after four months of courtship. 

In April 2020, she found out she was pregnant. The news was "positively received" by the couple. The next month, both their families met, mutually agreed that the couple should marry, and arranged to apply for a marriage license at the Local Civil Registrar on June 1, 2020. 

On the scheduled day, however, XXX's colleagues informed AAA that he would not be able to make it, as he was involved in a police operation. XXX had previously assured AAA he would ask his superiors for free time to carry out his wedding preparations. 

"AAA felt utterly humiliated and ashamed, having already informed her family and friends of the impending marriage license application," the decision read. 

Six days later, XXX reached out to AAA, apologized, and rescheduled another appointment with the LCR. They successfully filed their application for a marriage license on June 11, 2020. However, the following day, AAA learned that XXX had withdrawn their application, claimed AAA knew about it, and that his family and friends were against the marriage. 

According to an LCR employee, XXX had returned the same day the couple had filed their application and retrieved the documents, saying the marriage was not pushing through. 

AAA filed a case. She was examined by a psychometrician and an officer at the Municipal Social Welfare Development Office. The officer testified that AAA was "shaking and emotionally distraught while recounting her experiences" and was "not in a stable psychological and emotional state."

The psychometrician said AAA "suffered from restlessness, suicidal ideation, and depressive symptoms", adding these were caused by the withdrawn promise of marriage and her anxiety about her second pregnancy out of wedlock. 

XXX, on the other hand, maintained that he "never expressly agreed to marry AAA despite the pregnancy," the document read. He also said it was their families, not he, who set the date for the marriage license application. XXX asked to postpone the date, citing his seizure attacks and grandmother's illness, but he claimed AAA refused to move it. 

He claimed he only agreed to finally submit the application "because AAA became increasingly emotional." Contrary to the prosecution's testimony, XXX claimed he withdrew only his certificate of live birth, not the entire application, to use it to apply for a firearm license. 

Due to the prosecution's case, however, a warrant for his arrest had already been issued, and he voluntarily surrendered.

The decision

In December 2023, the Regional Trial Court found XXX "guilty beyond reasonable doubt" of violating the Anti-Violence Against Women and their Children Act of 2004. He was sentenced to imprisonment of two years, four months, and one day to 10 years and one day. Additionally, he was ordered to pay a fine of P100,000 and to undergo psychological counseling. 

XXX made an appeal which was denied by the Court of Appeals in a decision handed down in April 2025. Upholding the prison sentence, the CA ordered XXX to pay AAA P75,000 in moral damages and P75,000 in exemplary damages. 

Moral damages refer to compensation for inflicting non-physical harm to another, such as social humiliation and emotional anxiety. Exemplary damages are punitive, meant to punish a wrongdoer for their actions on top of the damage they had already done. 

The CA explained its decision was not because XXX broke his promise to marry per se but because of "the consequential effects of his actions that led to AAA being humiliated and publicly ridiculed."

"The malicious act of the unexplained withdrawal of the marriage license application was the means by which AAA endured emotional and mental suffering," the decision read. 

Additionally, the CA disagreed with XXX's claim that he was innocent. The Court wrote he was aware of "the negative emotional effects his actions would cause AAA and the scandal it would bring to her as a public school teacher. His subsequent marriage to another woman, only months after the withdrawn application, further belied his claim of innocence."