PELAYO v.

LAURON
G.R. No. 4089
JANUARY 12, 1909
J. TORRES

SUBJECT MATTER:
Support; Who are obliged to provide support

DOCTRINE(S) AND APPLICABLE CONCEPT(S):

Among the reciprocal obligations existing between a husband and wife is that of support, which obligation is established
by law.

Plaintiff-appellant: ARTURO PELAYO

Parties
Defendants-appellees: MARCELO LAURON, ET AL.

ANTECEDENT FACTS:
 Pelayo, a physician, rendered medical assistance to the child delivery of the daughter-in-law of the defendants.
 The just and equitable value of services rendered by him was P500.00, which the defendants refused to pay
without alleging any good reason.
 With this, the plaintiff prayed that the judgment be entered in his favor as against the defendants for the sum of
P500.00 and costs.
 The court below absolved the defendants from the complaint on account of the lack of sufficient evidence to
establish a right of action against the defendants

ISSUE(S) AND HOLDING(S):

WON the defendants are obliged to pay the petitioner for the medical assistance rendered to their daughter-in-law -- NO

RATIO:
The Court held that it is unquestionable that the person bound to pay the fees due to the plaintiff for the professional
services that he rendered to the daughter-in-law of the defendants during her childbirth is the husband of the patient and
not her father and mother- in-law.
 The rendering of medical assistance in case of illness is comprised among the mutual obligations to which
spouses are bound by way of mutual support. (Arts. 142 and 143.)
 In this case therefore, if the dead daughter-in-law could not pay for her childbirth expenses, then the burden will
fall on the husband.
o The party bound to furnish support is therefore liable for all expenses, including the fees of the medical
expert for his professional services
 It is only the husband, and not his parents who are bound to give support.
 The law does not compel any person to support a stranger unless such person bound himself to do so by an
express contract
o Since there was no contract agreed upon that the defendants will pay for the expenses, then they were
not liable.
o Within the meaning of the law, the father and mother-in-law are strangers with respect to the obligation
that falls upon the husband to give support

DISPOSITIVE:
Therefore, in view of the considerations hereinbefore set forth, it is our opinion that the judgment appealed from should be
affirmed with the costs against the Appellant. So ordered.

BLOCK 1-H (CARIÑO) – PERSONS & FAMILY RELATIONS, PROF. TRINIDAD-VARGAS