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

Case Summary (G.R. No. 4089)

Procedural Posture and Relief Sought

Pelayo filed suit on November 23, 1900, seeking judgment for P500 as the reasonable value of his professional services rendered during the childbirth, plus costs. The defendants denied the allegations, asserted the patient died as a result of the childbirth, and pleaded that the patient lived separately with her husband and any presence in the defendants’ house was accidental. The trial court ultimately absolved the defendants for lack of sufficient evidence to establish liability, awarded costs against Pelayo, and the plaintiff appealed. The Supreme Court reviewed the appeal; the appellate judgment was affirmed.

Key Dates

Complaint filed: November 23, 1900.
Childbirth and medical services rendered: on or about October 13, 1900.
Trial court amendment/order dates: January 23, 1907; judgment below: April 5, 1907.
Supreme Court decision: January 12, 1909.

Applicable Law

The court applied the Civil Code provisions in force at the time (Spanish Civil Code provisions as incorporated into local law). Articles cited and relied upon in the decision include Civil Code rules on obligations (arts. 1088–1091) and on the mutual obligations of spouses (arts. 142–143). The Court also referenced controlling Spanish jurisprudence (a May 11, 1897 decision of the Supreme Court of Spain) as persuasive authority on the limits of support obligations and contractual liability.

Facts Found or Assumed

The opinion assumes, for purposes of the legal question, that the defendants indeed summoned the plaintiff and that the plaintiff rendered medical services to the defendants’ daughter‑in‑law during a difficult childbirth, including use of forceps and removal of the afterbirth, and that he attended to the patient through the night and revisited her the same day. It is undisputed (as asserted by the defendants) that the patient lived with her husband in a separate household and that her presence in the defendants’ house may have been accidental.

Legal Issues Presented

Who is legally bound to pay the physician’s fees for services rendered to the wife during childbirth: the husband of the patient, or the wife’s parents (the defendants)?
Whether a person who summons a physician or in whose house the medical services occur is liable for the physician’s fees absent a contractual or legal obligation.

Legal Analysis and Reasoning

Nature of Obligations: The Court framed obligations under the Civil Code as arising from law, contract, quasi‑contract, and illicit acts (arts. 1088–1091). Obligations arising strictly from law must be expressly established by statute or code; they are not to be presumed beyond those provisions.
Spousal Mutual Support: The Civil Code provisions on spousal mutual support were interpreted to include the duty to furnish necessary medical assistance when a spouse falls ill. Because support obligations include giving and doing, the duty to procure medical services for an ill spouse (including payment of physician’s fees) flows from that statutory marital obligation.
Allocation of Liability: Given that the legal duty to provide medical assistance to a spouse arises from the marital obligation of support, the husband is the primary person legally bound to furnish and thus to pay for the indispensable medical services needed by his wife during childbirth. The husband’s duty is not defeated by the fact that he did not personally summon the physician; urgency and the statutory duty of support render the obligation enforceable against the husband regardless of who actually called the doctor.
No Legal or Contractual Obligation on Parents‑in‑Law: The parents‑in‑law (defendants) are strangers to the statutory obligation that devolves upon the husband; absent a contract, express agreement, or other legal basis creating liability, they cannot be compelled to pay. The simple facts that the physician was summoned by them or that the services took place in their house do not, in themselves, create a legal obligation to pay. The Court also cited the Spanish Supreme Court rule that a person is not liable to support a stranger absent a contract imposing that duty.
Effect of Plaintiff’s Pleading and Burden of Proof: Because the plaintiff sued the defendants and did not establish a contractual agreement or other legal basis obligating them to pay, the evidence was insufficient to impose liability on the defendants. The remedy of the physician lies against the husband, who alone bears the statutory support duty toward his wife.

Holding

The Supreme Court affirmed the lower court’s judgment absolving the defendants, holding that the husband—no

Case Syllabus (G.R. No. 4089)

Facts

On October 13, 1900, at night, the plaintiff Arturo Pelayo, a physician residing in Cebu, was called to the house of the defendants Marcelo Lauron and Juana Abella in San Nicolas to render medical assistance to their daughter-in-law who was about to give birth.
Upon arrival and after consultation with the attending physician Dr. Escano, the plaintiff found the birth difficult and removed the fetus by means of forceps; he also removed the after-birth and was occupied in this service until the following morning.
After the operation, on the same day, the plaintiff visited the patient several times.
The plaintiff alleged that the just and equitable value of his services was P500, which the defendants refused to pay without alleging any good reason.
The defendants, in their answer, denied the allegations in the complaint and specially alleged that the daughter-in-law had died as a consequence of the childbirth; that while alive she lived with her husband independently in a separate house with no relation to the defendants; and that, if she was in the defendants' house on the day of birth, her stay there was accidental and due to fortuitous circumstances.
The defendants requested dismissal of the plaintiff’s complaint and absolution from action with costs against the plaintiff.

Procedural History

Plaintiff filed complaint on November 23, 1900, seeking P500 and costs.
The defendants answered and raised the special defenses noted above.
The plaintiff demurred to the defendants’ answer; the court below sustained the demurrer and directed the defendants, on January 23, 1907, to amend their answer.
The defendants filed an amended answer on January 23, 1907, denying each allegation and requesting dismissal with costs.
After evidence by both parties, the court below rendered judgment on April 5, 1907, absolving the defendants from the complaint for lack of sufficient evidence to establish a right of action; costs were assessed against the plaintiff.
The plaintiff excepted to the judgment and moved for a new trial on the ground that the judgment was contrary to law; the motion was overruled and the plaintiff presented a bill of exceptions.
The defendants moved to eliminate from the judgment the declaration that they had demanded the plaintiff’s professional services, asserting the evidence did not support such a finding; that motion was denied and the defendants excepted.

Legal Issues Presented

Whether the defendants (the patient’s father and mother-in-law) were liable to pay the physician’s fees for professional services rendered to their daughter-in-law during a difficult childbirth.
Whether the plaintiff had a right of action against the defendants to recover P500 for his professional services.
Ancillary issue raised by the defendants’ motion: whether the judgment should declare that the defendants requested the plaintiff’s services when evidence may not have shown such a request.

Relevant Legal Provisions and Principles Cited

Civil Code article 1089: Obligations are created by law, by contracts, by quasi-contracts, and by illicit acts and omissions or by those in which any kind of fault or negligence occurs.
Principle that obligations arising from law are not presumed; only those expressly determined in the Code or in special laws are demandable.
Civil Code articles 1090 and 1091 summarized: obligations arising from contracts have legal force between contracting parties and must be fulfilled according to their stipulations.
Civil Code articles 142 and 143: rendering of medical assistance in case of illness is comprised among the mutual obligations to which spouses are bound by way of mutual support.
Civil Code article 1088: every obligation consists in giving, doing, or not doing something.
Spanish Supreme Court decision of May 11, 1897, recognizing that the law does not i