GR 150644; (August, 2006) (Digest)
G.R. No. 150644 August 28, 2006
EDWARD V. LACSON, Petitioner, vs. MAOWEE DABAN LACSON and MAONAA DABAN LACSON, represented by their mother and guardian ad-litem, LEA DABAN LACSON, Respondents.
FACTS
Petitioner Edward V. Lacson is the father of legitimate daughters Maowee and Maonaa. He left the conjugal home shortly after Maonaa’s birth in 1975. From 1976 to 1994, the respondents and their mother lived itinerantly, relying on meager and irregular financial assistance from Edward and his mother. Edward reneged on a written 1975 promise to provide support. In 1995, the sisters, through their mother as guardian ad-litem, filed a complaint for support before the RTC of Iloilo City. The trial court granted support pendente lite and, after trial, ordered Edward to pay support in arrears covering 18 years (1976-1994), deducting amounts previously received. The Court of Appeals affirmed the RTC decision.
ISSUE
Whether the Court of Appeals erred in affirming the award of support in arrears for the period 1976-1994 despite the absence of a prior judicial or extrajudicial demand.
RULING
The Supreme Court denied the petition and affirmed the CA decision. The Court rejected petitioner’s argument that his support obligation became demandable only from the 1995 judicial filing, citing Article 203 of the Family Code. The legal logic is that the provision’s purpose is to prevent accrual of support during periods of non-need, not to allow a neglectful parent to evade liability for past support when the need was continuous and manifest. The respondents’ need for support from childhood was constant and undeniable. Petitioner’s abandonment and persistent failure to fulfill his basic parental duty, despite knowledge of their precarious situation, constituted a constructive and continuing demand. Requiring a formal demand under these circumstances would be absurd and would reward parental neglect. The Court also found no merit in petitioner’s other claims regarding his financial incapacity or a prior sale of property allegedly satisfying the obligation, as these were unsubstantiated. The award of arrears was a proper rectification of a prolonged injustice.