G.R. No. 4089 - Pelayo vs. Lauron

Events of childbirth and medical services
On the night of October 13, 1900, plaintiff Arturo Pelayo, a physician residing in Cebu, was summoned by defendants Marcelo Lauron and Juana Abella at their house in San Nicolas to attend their daughter-in-law who was in difficult labor.
After consulting with Dr. Escano, Pelayo performed a forceps delivery, removed the after-birth, and remained in attendance until the following morning, making several subsequent visits. He charged P500 for his professional services, which the defendants refused to pay.

Complaint and procedural history
November 23, 1900: Pelayo filed suit for P500 plus costs. Defendants denied the allegations and pled as special defense that the patient lived separately with her husband, died from childbirth, and her presence in their house was accidental.
Trial court proceedings: Demurrer by plaintiff was sustained; defendants filed an amended answer on January 23, 1907. After evidence was heard, April 5, 1907 judgment absolved defendants for lack of proof. Plaintiff’s motion for new trial was denied and he appealed to the Supreme Court.

Liability of the in-law defendants
Are Marcelo Lauron and Juana Abella obligated to pay the physician’s fees in the absence of any contract?
Does the defendants’ special defense regarding the patient’s separate domicile and accidental stay bar their liability?

Liability of the husband
Is the husband of the patient bound by law to pay for medical services rendered to his wife during childbirth?
Do Civil Code arts. 142 and 143 on mutual spousal support impose on the husband the duty to pay the physician’s fees?