G.R. No. 17014 - Arroyo vs. Vazquez de Arroyo

Mariano B. Arroyo and Dolores C. Vazquez de Arroyo were married in 1910 and, notwithstanding a few brief separations, cohabited as husband and wife in Iloilo until July 4, 1920, when the wife left the marital home intending to live apart permanently.
The husband subsequently filed an action to compel her to return and resume conjugal relations. In her answer, the wife admitted leaving without his consent but counterclaimed that she was forced to depart due to alleged cruel treatment by her husband.
The trial court ruled in favor of the wife, granting her a decree of separation with alimony of P400 per month and ordering the husband to pay her attorney’s fees of P1,000.
Upon appeal, the evidence was re-examined, and it was determined that the wife’s departure was principally attributable to her aggravated disposition of jealousy rather than sufficient misconduct by the husband.
The record showed no evidence of conjugal infidelity or clear proof of legal cruelty justifying the separation, with the “cruelty” claims being deemed as exaggerated personal quarrels rather than legal grounds for abandonment.

Whether the wife’s abandonment of the marital home was justified by her claims of cruelty, or whether her personal disposition and conduct rendered her separation without sufficient legal cause.
Whether a mandatory injunction compelling the wife to resume cohabitation (the restitution of conjugal rights) is a permissible judicial remedy in this jurisdiction.
The extent to which the husband’s claim to the resumption of marital relations is enforceable under the law, taking into account the proper boundaries concerning the enforcement of personal rights such as consortium.