G.R. No. L-11086 - Atilano vs. Chua Ching Beng

Pilar Atilano and Chua Ching Beng were lawfully married in May 1951 in Zamboanga City.
The couple immediately sailed for Manila and established residence with the husband’s parents.

In October 1951, at the husband’s initiative, the couple visited the wife’s parents in Zamboanga City.
During the visit, the wife’s parents persuaded the husband to return to Manila, leaving the wife temporarily behind with the understanding that she would later join him in Manila.
The wife ultimately did not follow the husband back to Manila, which contributed to their separation.

On September 30, 1953, Pilar Atilano filed a complaint for support with the Court of First Instance of Zamboanga.

Alleging that the couple had lived apart since October 1952 due to persistent marital strife, primarily attributed to incessant bickering and quarrels.
Asserting that the estrangement was largely due to the inability to establish a home separate from the husband’s parents and the undue influence exerted by the wife’s own parents.
Claiming that she had no employment or property of her own and was residing with her parents.
Demanding that the husband provide a monthly allowance of P200 starting from the filing date of the complaint.

Contended that their earlier married life in Manila was harmonious.
Maintained that the separation occurred because the wife’s parents, who influenced her decision, caused her alienation and prevented her from rejoining him in Manila.
Argued that the husband was not shirking his support obligations, but rather preferred to discharge these obligations by keeping his wife in Manila.
Asserted his right, under his role as husband, to determine the couple’s residence and even expressed readiness to establish a conjugal dwelling separate from his parents if demanded by his wife.

Concurrently with the support complaint, the wife filed a petition for alimony pendente lite.
The court, on May 3, 1954, rendered judgment granting her an allowance of P75 monthly.

The decision was based on findings revealing that the wife’s refusal to live with the husband was influenced by her aversion to residing with the husband’s parents after previously encountering in-law troubles.
The lower court also noted that no substantive evidence corroborated allegations of incompatibility and habitual marital quarrels.

Subsequently, the husband petitioned to fulfill his support obligation by having the wife receive and be maintained in his residence in Pasay City, which was apart from his parents’ home.

When the defendant’s petition was denied, he elevated the issue to the Court of Appeals.
The Court of Appeals certified the case to the Supreme Court pursuant to Section 17-6 of Republic Act No. 296.

The underlying controversy revolved around whether the wife, who chose to live apart owing to domestic misunderstandings with her husband’s relatives, was still entitled to receive support from her husband.

Whether a wife is entitled to receive support from her husband when she refuses to live with him, specifically due to misunderstandings with his immediate relatives.

Whether the husband’s election to support his wife by receiving and maintaining her in his house, rather than providing a fixed monetary allowance, is valid under Article 299 of the Civil Code.
Whether the presence of domestic conflict with in-laws would legally or morally constitute an obstacle to the husband’s exercise of his option under the said law.

Whether the husband’s willingness to establish a conjugal dwelling separate from his parents’ home, if desired by the wife, alters his obligation to provide support.