Valentine’s Day is a celebration of love in all its forms; romantic, platonic, and self-love. But beyond the flowers, chocolates, and grand gestures, love is also governed by the law. The Philippine Supreme Court has ruled on cases that touch on relationships, marriage, and the consequences of love lost. This Valentine’s Day, let’s explore some key decisions where the law met the matters of the heart.

Love Should Be Free, Not Forced

“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 circumstances.

For this reason, litigation to the sorrows caused by a broken heart and a broken promise must be discouraged.”

The Supreme Court, in Jhonna Guevarra et al. vs. Jan Banach (G.R. No. 214016, November 24, 2021), affirmed that love and marriage should be choices made freely, without fear of legal repercussions. The ruling emphasized that an individual has the autonomy to decide whether to marry or not, and that backing out of a relationship, even an engagement, should not be grounds for a civil suit.

Valentine’s Day often comes with pressure: grand proposals, social media expectations, and the assumption that love must always lead to marriage. But this case reminds us that the heart must be given freely, not out of obligation. Love that is coerced is not love at all. Sometimes, the greatest act of love is having the courage to walk away when you know the relationship is not right.

When Love Defies Norms

“With the finding that there is no substantial evidence of the imputed immoral acts, it follows that the alleged violation of the Code of Ethics governing school teachers would have no basis. Private respondent utterly failed to show that petitioner took advantage of her position to court her student. If the two eventually fell in love, despite the disparity in their ages and academic levels, this only lends substance to the truism that the heart has reasons of its own which reason does not know. But, definitely, yielding to this gentle and universal emotion is not to be so casually equated with immorality. The deviation of the circumstances of their marriage from the usual societal pattern cannot be considered as a defiance of contemporary social mores.”

In Chua-Qua v. Clave (G.R. No. L-49549), the Court recognized that love is not bound by societal expectations. The case involved a teacher and her former student, a relationship that was scrutinized due to their age gap and academic positions. However, the Court ruled that their love was not immoral simply because it deviated from the norm. As the decision poetically put it, “the heart has reasons of its own which reason does not know.”

This echoes the spirit of Valentine’s Day: love is unpredictable, and sometimes, it blooms in places where society least expects it. Whether it’s an unconventional pairing, a love that defies distance, or a romance that starts later in life, what truly matters is mutual respect and sincerity.

Consent, Even in Marriage

“Husbands are once again reminded that marriage is not a license to forcibly rape their wives. A husband does not own his wife’s body by reason of marriage. By marrying, she does not divest herself of the human right to an exclusive autonomy over her own body and thus, she can lawfully opt to give or withhold her consent to marital coitus. A husband aggrieved by his wife’s unremitting refusal to engage in sexual intercourse cannot resort to felonious force or coercion to make her yield. He can seek succor before the Family Courts that can determine whether her refusal constitutes psychological incapacity justifying an annulment of the marriage.”

Not all love stories are fairytales. Some turn dark, where love is used as a weapon rather than a gift. In People v. Jumawan (G.R. No. 187495, 2014), the Court made it clear that marriage is not a license for a husband to force himself upon his wife. A wife retains full autonomy over her body, even within the bonds of marriage. If she withholds consent, her husband has no right to force her.

Valentine’s Day may be about passion, but it must always be grounded in respect. Love is not about possession, and marriage does not erase a person’s right to say “no.” True love listens, honors, and never coerces.

A Valentine’s Reflection

Love, as celebrated on Valentine’s Day, is both a privilege and a responsibility. The law, much like the holiday, recognizes that love cannot be forced, must not be judged unfairly, and must always be rooted in consent. As we celebrate love in its many forms, these legal rulings serve as a reminder that beyond romance, love must always be accompanied by freedom, respect, and dignity.

So this Valentine’s Day, whether you are in love, heartbroken, or simply enjoying your own company—remember: love is beautiful, but it should never come at the cost of your autonomy.

HAPPY VALENTINE’S DAY!

Love,

Ana 💋

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