Case Summary (G.R. No. 150644)
Factual Background: Abandonment, Failure to Support, and Family Circumstances
Maowee was born on December 4, 1974, while Maonaa was born less than a year later. Soon after Maonaa’s birth, Edward left the conjugal home in Molo, Iloilo City, effectively forcing Lea and the children to seek shelter elsewhere, allegedly for financial reasons. Initially, they stayed with Lea’s mother-in-law, Alicia Lacson; later, they moved in with Lea’s mother; and later still, they stayed with Lea’s brother, Noel Daban. They also rented an apartment at one point and subsequently returned to Lea’s mother’s house.
The trial court characterized the arrangement from 1976 to 1994 as a recurring pattern: the sisters and their mother shuttled for eighteen (18) years from one dwelling place to another not their own. From the start of their estrangement, Lea did not badger Edward for support at first and relied on a written commitment Edward made in a note dated December 10, 1975 promising support for their daughters. Over time, however, Edward reneged on that commitment, though he would occasionally give the children meager amounts for school expenses. During the period up to the middle part of 1992, Edward’s mother, Alicia Lacson, also gave small sums to assist in schooling. Both sisters eventually took up nursing at St. Paul’s College in Iloilo City.
Initiation of the Support Case and the Trial Court’s Interim Order
In early 1995, when Maowee was about to graduate, Lea, in behalf of the two daughters, filed a complaint against Edward for support before the RTC of Iloilo City, Branch 33. The complaint was dated January 30, 1995, as amended, and was docketed as Civil Case No. 22185. The complaint alleged that Edward, though gainfully employed and owning valuable lands, had not provided support since 1976. It further alleged that Lea had borrowed money from her brother, Noel Daban, because of Edward’s continuing failure and neglect. Lea later testified that Noel had loaned amounts ranging from PHP 400,000.00 to PHP 600,000.00.
Edward denied neglect as the cause of non-support and averred that he had given sufficient sums to meet the children’s needs. He claimed, instead, that lack of regular income and the unproductivity of inherited land, rather than neglect, explained his inability at times to give regular support. He also asserted financial constraints in relation to the PHP 12,000.00 monthly allowance prayed for.
After due hearing, the trial court granted support pendente lite at PHP 12,000.00 per month, subject to payment schedule and conditions set in the order dated May 13, 1996.
RTC Judgment on the Merits: Award of Support in Arrears and Attorney’s Fees
Following trial, the RTC rendered its judgment on June 26, 1997, ruling in favor of Maowee and Maonaa as represented by their mother. The RTC computed support in arrears based on an “elaborate formula” in the decision and ordered Edward to pay a sum representing 216 months, or eighteen (18) years, of support in arrears. The RTC’s fallo ordered: (1) Edward to pay PHP 2,496,000.00 as support in arrears, from which PHP 124,000.00 would be deducted as the amounts the daughters had received for two years and amounts received by way of support pendente lite; (2) Edward to pay PHP 20,000.00 as attorney’s fees; and (3) costs.
Proceedings Before the Court of Appeals
Edward appealed to the CA, docketed as CA-G.R. CV No. 60203. The CA dismissed Edward’s appeal and affirmed the RTC Decision in a Decision dated July 13, 2001, and it ordered double costs against Edward.
Edward moved for reconsideration, but the CA denied the motion in its Resolution dated October 18, 2001.
Issues Raised by Petitioner
In his petition before the Supreme Court, Edward attacked the CA affirmance on several grounds: that the CA erred in affirming support in arrears from 1976 to 1994 absent any prior extrajudicial or judicial demand; that the CA erred in affirming the alleged advances of support by Noel Daban; that the award was improper because Edward was allegedly not financially capable to provide support; and that, because of a later transaction involving the sale of property allegedly exclusive to Edward with proceeds purportedly appropriated by Lea and the sisters, his obligation to pay support had already been fully satisfied.
Legal Basis on Demand: Article 203 and the Meaning of “Demand”
Edward relied on Article 203 of the Family Code, arguing that the obligation to give support is demandable from the time the recipient needs it for maintenance, but it is not paid except from the date of judicial or extrajudicial demand. He contended that support could only start to run from the filing of Civil Case No. 22185 in 1995, because that was when an effective demand was made.
The Court rejected the posture. It emphasized that Edward had left the conjugal home long before the children were even of tender years, and the estrangement made it implausible to expect the daughters during their early lives to demand support. It also highlighted that even the mother found it difficult during the material period to get in touch with Edward. Most significantly, the Court found that the CA and the RTC both determined that the requisite demand had been made earlier.
The December 10, 1975 Note as Evidence of Extrajudicial Demand
The Court treated the demand issue as factual and tied it to the December 10, 1975 note where Edward committed himself to support his children. The trial court found that from 1976, Lea “now and then” went to the paternal grandmother’s house and asked for support, notwithstanding Edward’s commitment embodied in the note. The trial court also stated that Lea asked extrajudicially for the children’s support since 1976 when she went to her mother’s house.
On appeal, the CA likewise held that Edward could not avoid liability by insisting on a formal demand. It found Edward’s own acknowledgment and commitment through the note to be practically confirming that a demand had been made by the children’s mother. The Supreme Court accorded respect to the concurrent factual findings of the RTC and CA. It reiterated the rule on the conclusiveness of the CA’s factual findings, absent compelling reasons under recognized exceptions. No such exception was shown. It therefore refused to disturb the finding that there had been an extrajudicial demand, as evidenced by the December 10, 1975 note and Lea’s requests for support.
In the same frame, the Court explained that its jurisdiction in a Rule 45 petition was generally confined to errors of law and did not require reweighing of evidence already passed upon, absent compelling justification.
Noel Daban’s Advances and Article 207: Reimbursement by the Person Obliged to Support
Edward next challenged the CA ruling that Noel Daban advanced money for the daughters’ support. The Supreme Court treated this as again a matter that required review of factual determinations, which it declined for the same reasons.
The Court nevertheless addressed the logic of the lower courts’ conclusion. It noted that among close relatives, the sisters stayed the longest with Noel Daban. It also observed that from 1976 to 1994, Edward provided only “token amounts” for schooling when support includes all necessities for sustenance, dwelling, clothing, medical attendance, and education. Given Edward’s failure spanning the daughters’ pre-schooling years through college, the Court reasoned that it was logical for the sisters, through Lea, to turn to Noel Daban for sustenance and education.
With that factual foundation, the Court upheld the reimbursement principle under Article 207 of the Family Code, which provides that when a person obliged to support unjustly refuses or fails to give support when urgently needed, any third person may furnish support and may seek reimbursement from the person obliged to support. The Court added that the relationship created by such circumstances could be viewed through the lens of a quasi-contract and the equitable principle against unjust enrichment.
Amount of Support and Petitioner’s Capacity
Edward also argued that he should not be made to pay support even if he was allegedly not financially capable. The Supreme Court found no legal or factual basis to disturb the “absolute figures” arrived at by the RTC and CA, because the courts’ computations were considered reasonable and proper. The Court stated that the amount was based on the varying needs of the respondents during the years included in the computation and on Edward’s financial resources as proved in evidence.
It reiterated the legal principle that support obligations among relatives generally depend on the resources or means of the giver and the needs of the recipient, and it cited Article 201, Family Code, along with Baltazar v. Serfino, No. L. 17315, July 31, 1965, 10 SCRA 189.
Post-Judgment Sale of Property and the Claim of Satisfaction
Finally, Edward urged the Court to consider a transaction that occurred after the RTC rendered judgment: Lea’s sale of half of what Edward asserted was his exclusive or capital property, allegedly with proceeds of PHP 5 Million appropriated by Lea and the sisters. He claimed the proceeds were more than enough to satisfy and thereby release him from compliance with the support judgment, at least ex gratia.
The Court rejected this submission
...continue reading
Case Syllabus (G.R. No. 150644)
Parties and Procedural Posture
- Edward V. Lacson appeared as the petitioner and was the father of Maowee Daban Lacson and Maonaa Daban Lacson.
- Maowee and Maonaa Daban Lacson, represented by their mother and guardian ad-litem Lea Daban Lacson, appeared as the respondents.
- The case reached the Supreme Court by a petition for review under Rule 45 of the Rules of Court.
- The petition sought reversal of the Court of Appeals (CA) Decision dated July 13, 2001 in CA-G.R. CV No. 60203, as reiterated by the CA Resolution dated October 18, 2001 denying reconsideration.
- The CA had dismissed Edward’s appeal and affirmed the Regional Trial Court (RTC) ruling in Civil Case No. 22185 for support.
Family Relationship and Background
- The respondents were legitimate daughters of Edward V. Lacson and Lea Daban Lacson.
- Maowee was born on December 4, 1974, while Maonaa was born about a year later.
- After the birth of Maonaa, petitioner left the conjugal home in Molo, Iloilo City, effectively compelling mother and children to seek shelter elsewhere.
- The family’s housing circumstances from 1976 to 1994 involved repeated transfers among relatives and rented premises, as found by the trial court.
Estrangement and Support History
- The trial court found that from the start of estrangement, Lea did not badger Edward for support, relying initially on Edward’s commitment evidenced by a note dated December 10, 1975.
- Edward later reneged on his promise of support despite Lea’s efforts to have him comply.
- The record reflected that Edward occasionally gave their children meager amounts for school expenses.
- Up to about the middle of 1992, Edward’s mother, Alicia Lacson, also provided small assistance for the sisters’ schooling.
- The sisters eventually pursued nursing at St. Paul’s College in Iloilo City, which increased the importance of continued support for sustenance, dwelling, education, and medical attendance.
Initiation of Support Case
- In the early part of 1995, Lea, on behalf of her two daughters, filed a complaint for support before the RTC of Iloilo City, Branch 33.
- The complaint was dated January 30, 1995, docketed as Civil Case No. 22185, and later amended.
- The complaint alleged that Edward, despite being gainfully employed and owning valuable lands, failed to provide support since 1976.
- The complaint further alleged that Lea had borrowed money from her brother Noel Daban because of Edward’s neglect and failure to support the children.
- Lea later testified that she received P400,000.00 to P600,000.00 from Noel Daban by way of loan.
Petitioner’s Defense and Trial Court Measures
- In his Answer, Edward alleged he had given Maowee and Maonaa sufficient sums to meet their needs.
- Edward claimed his failure at times to provide regular support resulted from lack of regular income and unproductivity of lands he inherited, not neglect.
- Edward blamed financial constraints for his inability to provide the prayed P12,000.00 monthly allowance.
- The RTC granted support pendente lite at P12,000.00 per month, subject to the conditions stated in its order dated May 13, 1996.
RTC Judgment for Arrears
- After trial, the RTC rendered judgment on June 26, 1997 in favor of the plaintiff sisters represented by their mother.
- The RTC’s fallo ordered Edward to compensate the sisters for support in arrears computed over 216 months (interpreted as 18 years).
- The RTC ordered the payment of P2,496,000.00 for support in arrears, with a deduction of P124,000.00 corresponding to what the sisters received for two years and what they received as support pendente lite.
- The RTC also awarded P20,000.00 as attorney’s fees and ordered Edward to pay the costs.
Issues Raised on Appeal
- Edward appealed to the CA, which later affirmed the RTC decision and dismissed his appeal.
- In his Supreme Court petition, Edward raised these core contentions:
- The CA erred in affirming support in arrears from 1976 to 1994.
- The CA erred in affirming advances of support attributed to their uncle Noel Daban.
- The CA erred in affirming support even if petitioner was not financially capable.
- The CA erred in ordering support despite petitioner’s claim that his obligation had been satisfied by proceeds of the sale of his alleged exclusive property.
Family Code Rules on Demand
- Edward anchored his principal argument on Article 203 of the Family Code, which states that the obligation to give support becomes demandable when the recipient needs it, but it is not paid except from the date of judicial or extrajudicial demand.
- Edward insisted that the obligation to pay arrears shoul