Lacson v. Lacson
REITERATIONFacts
The Antecedents: The underlying dispute concerns the obligation of a father, Edward V. Lacson, to provide financial support to his two daughters, Maowee Daban Lacson and Maonaa Daban Lacson. The daughters, through their mother and guardian ad litem, Lea Daban Lacson, alleged that their father had failed to provide adequate support since 1976, despite being gainfully employed and owning valuable properties. This alleged neglect forced their mother to borrow substantial sums and rely on the occasional, meager financial assistance from the paternal grandmother and the daughters' uncle, Noel Daban, to cover their basic needs, including education. Procedural History: The daughters, represented by their mother, filed a complaint for support in arrears against their father in the Regional Trial Court (RTC) of Iloilo City in 1995. The RTC granted provisional support pendente lite and, after trial, rendered a judgment ordering the father to pay support in arrears for 216 months (18 years), totaling P2,496,000.00, plus attorney's fees and costs. The father appealed this decision to the Court of Appeals (CA). The CA dismissed the appeal and affirmed the RTC's decision. The father's subsequent motion for reconsideration was denied by the CA. The Petition: The father, Edward V. Lacson, has filed a petition for review under Rule 45 of the Rules of Court, seeking to reverse the CA's decision. He raises four main arguments: (1) the CA erred in affirming the grant of support in arrears from 1976 to 1994 without a prior judicial or extrajudicial demand; (2) the CA erred in affirming the alleged advances of support by their uncle, Noel Daban; (3) the CA erred in affirming the award of support despite his alleged financial incapacity; and (4) the CA erred in ordering him to provide support when he claims his obligation has been satisfied by the proceeds from the sale of his exclusive property, which he alleges were appropriated by the respondents.
Issue(s)
Whether the Court of Appeals erred in affirming the grant of support in arrears from 1976 to 1994. Whether the Court of Appeals erred in affirming the alleged advances of support by respondents' uncle, Noel Daban. Whether the Court of Appeals erred in affirming the award of support despite the petitioner's alleged financial incapacity. Whether the Court of Appeals erred in affirming the award of support even if the petitioner's obligation was allegedly completely satisfied by the proceeds of the sale of his exclusive property.
Ruling
The petition is denied, and the appealed decision and resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the grant of support in arrears from 1976 to 1994: The Court held that the petitioner's contention that support is only demandable from the date of judicial or extrajudicial demand under Article 203 of the Family Code is without merit. The Court found that the petitioner had virtually abandoned the respondent sisters from their early childhood. Furthermore, the mother's efforts to secure support, including her visits to the paternal grandmother and the petitioner's own commitment note dated December 10, 1975, constituted sufficient extrajudicial demand. Both the trial court and the Court of Appeals made parallel findings on the actuality of such demand, which the Supreme Court found no reason to disturb, adhering to the rule on the conclusiveness of factual findings of the CA. The Court emphasized that a request or plea for support, especially in urgent situations, is no less a demand. On the alleged advances of support by Noel Daban: The Court found no reason to disturb the CA's holding that respondents' uncle, Noel Daban, advanced money for their support. Given the petitioner's failure to provide adequate support from 1976 to 1994, it was logical for the sisters, through their mother, to turn to their uncle for sustenance and education. The Court cited Article 207 of the Family Code, which allows any third person to furnish support to a needy individual with the right of reimbursement from the person obliged to give support, establishing a quasi-contractual relationship. The amount of support in arrears was deemed reasonable and proper, fixed based on the respondents' needs and the petitioner's financial resources. On the petitioner's alleged financial incapacity: The Court reiterated that the amount of support is generally determined by the resources of the giver and the needs of the recipient. The petitioner's claim of financial incapacity was not sufficiently substantiated to override the findings of the lower courts, which had based their computation on the evidence adduced during the trial regarding his financial resources and the respondents' needs. The Court noted that the petitioner had been gainfully employed and owned valuable lands, contradicting his claims of inability to provide support. On the satisfaction of obligation by sale of exclusive property: The Court found the petitioner's submission flawed. Firstly, there was no showing that the property sold was exclusively his; the CA noted that it could be conjugal property, and the mother asserted they separately sold their respective shares. Secondly, the respondent sisters were not parties to the sale, making the petitioner's suggestion that proceeds went to them and should be set off against his debt gratuitous and self-serving. The Court concluded that the petitioner had been remiss in his duty to provide support, and the disposition was a measure to right the wrong done to the respondents.
Main Doctrine
The obligation to give support is demandable from the time the person who has a right to receive it needs it, but payment is only due from the date of judicial or extrajudicial demand. However, a formal demand is not always necessary, especially when the obligor has abandoned the recipients and their mother has made efforts to secure support. A third person who provides support to a needy individual due to the unjust refusal or failure of the obligor to provide it has the right of reimbursement from the obligor.