Love on the bench: How the Supreme Court writes about the heart

On Valentine’s Day, most love stories are found in poems, playlists, and candlelit tables. Yet some of the most striking reflections on love and marriage in the Philippines are hidden in an unlikely place: the decisions of the Supreme Court, written in the language of law but pulsing with the emotions of real relationships.

In 2021, the ruling in Rosanna L. Tan-Andal v. Mario Victor M. Andal (G.R. No. 196359, 11 May 2021), penned by Justice Marvic M.V.F. Leonen, a case on psychological incapacity, captured public attention not only for reshaping doctrine but for how it spoke about love itself. The Court described love as a promise “to seek beyond ourseltor to enable the other to continue to become the best version of themselves,” hinting that being in love is revealed in quiet, everyday acts of unconditional care and comfort.

It stressed that “marriage is not compulsory when in love; neither does it create love,” presenting marriage as a shelter of legal and public recognition, but never a spell that can summon or revive affection. For a ruling that ultimately declared a marriage null, it read, at times, like a gentle letter to couples about responsibility, tenderness, and the painful courage to part when staying together wounds more than it heals.

Long before Tan-Andal, the Court was already writing frankly about the cruelty of emotional abandonment. In Chi Ming Tsoi v. Court of Appeals and Gina Lao-Tsoi (G.R. No. 119190, 16 January 1997), authored by Justice Jose A.R. Torres Jr., a case involving a sexless marriage, the justices declared that “love is useless unless it is shared with another” and described as “the cruelest act of a marriage partner” the attitude of saying, “I could not have cared less.”

The decision reminded couples that marital union is a “two-way process” and that marriage is “not for children but for two consenting adults” who approach it with love, respect, sacrifice, and a continuing commitment to compromise. In a season often dominated by grand gestures and public displays, the Court’s message feels quietly radical: it is the daily decision to listen, show up, and care that truly keeps a marriage alive.

In Patricia Figueroa v. Simeon Barranco Jr. (SBC Case No. 519, July 31, 1997), written by then Chief Justice Andres R. Narvasa, and born of a long-ago romance with a man who later chose another partner, the Court delivered another line that has echoed far beyond the legal community: “We cannot castigate a man for seeking out the partner of his dreams, for marriage is a sacred and perpetual bond which should be entered into because of love, not for any other reason.” Between the formal phrases lies a tender but firm conviction — that marriage, for all its legal consequences, must begin where the heart truly rests, and not where convenience, pressure, or fear would push it.

Other rulings confront the limits of romance and the fragile, changing nature of the heart. In Rowena Padilla-Rumbaua v. Edward Rumbaua (G.R. No. 166738, August 14, 2009), with the opinion written by Justice Arturo D. Brion, the Court observed that people in love have the power “to let love grow or let love die,” a choice faced when reality no longer resembles the love they once imagined.

It is a rare acknowledgment, from the country’s highest tribunal, that even the most passionate vows can be worn thin by time, neglect, or unresolved wounds. In reading these words, one hears not only a court deciding a case but a quiet recognition that every petition is also the story of two people learning that love is not always enough to stay.

The justices have been equally clear that not every broken heart belongs in a courtroom. In Guevarra, et al. v. Banach (G.R. No. 214016, November 24, 2021), also penned by Justice Leonen, and in similar cases involving broken engagements and failed romantic promises, the Court underscored that while broken promises can leave deep scars, the autonomy to choose whom to marry — or whether to marry at all — is fundamental.

The law may address concrete harm, but it cannot compel someone to remain, rekindle affection, or love on command. Hidden behind the legal reasoning is a simple truth: the freedom to love includes the freedom to walk away, even when it hurts.

Money and power within relationships have also drawn some of the Court’s strongest language. In People v. Lito Egan alias Akiao (G.R. No. 139338, May 28, 2002), with the decision written by Justice Jose C. Vitug, the Court warned that while people like to say “love is free,” money — including dowry or lavish gifts — is never a legitimate “consideration” for passion and affection, nor does it grant a license to treat another person as an object.

True love, it suggested, cannot be bought, bargained, or coerced; it can only be freely given, grounded in consent and respect. If Valentine’s Day sometimes risks turning affection into a transaction, the Court’s words return us to the heart of the matter: dignity is non-negotiable, even in the most intimate of bonds.

Every February, law students and young lawyers rediscover these lines, turning them into “hugot” posts, speeches, and even whispered quotes at weddings and anniversaries. Legal writers and professors compile passages from Tan-Andal, Chi Ming Tsoi, Figueroa, Padilla-Rumbaua, Guevarra, and Egan, slowly forming an unofficial anthology of how the law sees love, marriage, and the right to begin again. What started as judicial language resolving disputes has become, in many ways, a mirror of how a nation understands commitment and heartbreak.

Read together, these decisions sketch a quiet philosophy of love in Philippine jurisprudence. Love is cherished, but never romanticized to the point of excusing cruelty or neglect. Marriage is honored as a sacred bond, yet the courts recognize that some unions are flawed from the start — fractured by psychological incapacity, betrayal, or years of silence. Personal autonomy is protected: no one can be forced to say “I do,” remain in a union that has emptied itself of care, or pretend that love lives on where it has long since gone.

On this Valentine’s Day, as roses wilt slightly in their vases and handwritten notes are tucked into drawers, the Supreme Court’s words offer a different kind of love letter — one drafted in formal prose, stamped with G.R. numbers, but rooted in the same longings and fears that fill every human heart.

Between Tan-Andal v. Andal (G.R. No. 196359, Justice Leonen), Chi Ming Tsoi v. CA (G.R. No. 119190, Justice Torres Jr.), Figueroa v. Barranco (SBC Case No. 519, Chief Justice Narvasa), Padilla-Rumbaua v. Rumbaua (G.R. No. 166738, Justice Brion), Guevarra v. Banach (G.R. No. 214016, Justice Leonen), and People v. Egan (G.R. No. 139338, Justice Vitug), a single theme emerges: love is both feeling and choice, freedom and responsibility, joy and, sometimes, the quiet, devastating bravery to let go so that both hearts may finally heal.

As the city lights dim and only the soft glow of bedroom lamps and courthouse night bulbs remain, these decisions remind us that love does not live only in sonnets and songs. It lives, too, in petitions and pleadings, in the trembling signatures of those who chose to stay and those who chose to finally go.

Somewhere between the cold precision of a dispositive portion and the warmth of a well-placed metaphor, the justices have traced the outline of the human heart: capable of promise, vulnerable to failure, yet always reaching for grace. And if there is one quiet blessing to be found in these pages, it is this — that even when love arrives late, leaves early, or returns in unexpected forms, the law still makes room for it, recognizes its power, and gently concedes that some questions can only be answered by the heart itself.