GR 131286; (March, 2004) (Digest)
G.R. No. 131286; March 18, 2004
JOSE LAM, petitioner, vs. ADRIANA CHUA, respondent.
FACTS
Adriana Chua filed a petition to declare her marriage to Jose Lam null and void on the ground of his psychological incapacity. During the proceedings, evidence revealed that Jose had contracted two prior marriages, which were still subsisting at the time of his marriage to Adriana. Consequently, the Regional Trial Court (RTC) of Pasay City declared the marriage null and void ab initio on the ground of bigamy. In the same decision, the RTC ordered Jose to provide monthly support of ₱20,000.00 for their son, John Paul. Jose moved for reconsideration solely on the support aspect, arguing that a prior compromise agreement, approved by the Makati RTC in a separate proceeding for the dissolution of their conjugal partnership, already provided for the child’s support. This agreement required both parties to contribute ₱250,000.00 each to a common fund for their son’s benefit. The Pasay RTC denied his motion, and the Court of Appeals affirmed the decision.
ISSUE
Whether the award of monthly child support by the Pasay RTC is valid, considering the existence of a prior court-approved compromise agreement between the parties that established a common fund for the child’s support.
RULING
The Supreme Court denied the petition and affirmed the award of monthly support. The legal logic is anchored on the distinct nature and purpose of the two judicial orders. The compromise agreement approved by the Makati RTC governed the dissolution of the conjugal partnership and the separation of properties. Its provision for a common fund was a contractual arrangement between the spouses regarding the management of their properties for the child’s benefit. In contrast, the subsequent order for monthly support issued by the Pasay RTC in the nullity case is a judicial decree rooted in parental obligation. This obligation, imposed by law under Articles 195 and 194 of the Family Code, is a personal duty of parents to support their children, which is demandable and cannot be evaded by a prior property settlement.
The Court emphasized that the parental duty to support is separate from property relations between spouses. The compromise agreement did not extinguish Jose’s ongoing legal duty to provide adequate support, which is determined by the needs of the child and the capacity of the parent. Since the Pasay RTC’s decision declared the marriage void, it had the concomitant duty to provide for the child’s support. The award of ₱20,000.00 monthly was proper as Jose did not present evidence to contest his capacity to pay or the reasonableness of the amount during the trial. Therefore, the prior agreement on a common fund does not bar a subsequent court from ordering periodic support to ensure the continuous fulfillment of a parent’s essential legal obligation.