G.R. No. L-18135; July 31, 1963
BASILIO S. FALCON, deceased substituted by his wife LOURDES BURGOS and children ARNULFO FALCON, FE FALCON, SILVESTRE FALCON, EMILIO FALCON, and BLANQUITA FALCON, petitioner, vs. HON. FRANCISCO ARCA, in his capacity as Presiding Judge of the Court of First Instance of Laguna, Second Branch, and ROBERTO FALCON, respondents.

FACTS

Roberto Falcon filed an action for support against Basilio S. Falcon, claiming to be his illegitimate son. The trial court dismissed the complaint, but the Court of Appeals reversed the decision. It declared Roberto an illegitimate child entitled to support and ordered Basilio to pay a monthly support of P50.00 “until the plaintiff reaches the age of majority or finishes some profession or trade.” Basilio complied until December 31, 1960, when he ceased payments upon Roberto reaching the age of majority on December 27, 1960.
Roberto then filed a petition in the trial court, praying that Basilio be ordered to continue support until he completed his education or vocational training. Respondent Judge Francisco Arca issued an order on February 17, 1961, directing Basilio to continue the monthly support payments. Basilio assailed this order via certiorari, arguing it was issued without or in excess of jurisdiction. He contended that under the appellate court’s decision, his obligation extinguished upon Roberto’s attainment of majority age, which occurred first. During the pendency of this Supreme Court proceeding, Basilio S. Falcon died.

ISSUE

Whether the respondent Judge acted without or in excess of jurisdiction in ordering the continuation of support payments beyond Roberto Falcon’s age of majority.

RULING

The Supreme Court denied the petition, ruling that the respondent Judge acted correctly and within his jurisdiction. The legal logic centers on the proper interpretation of the final and executory decision of the Court of Appeals. The High Court clarified that the issue was one of interpreting that judgment to ascertain its legal operation and effect, a question of law within its competence.
The Court of Appeals’ judgment, written in Spanish, ordered support “hasta que el demandante llegue al la mayoria de edad o termine alguna profesion u oficio” (until the plaintiff reaches the age of majority or finishes some profession or trade). The Supreme Court interpreted this dispositive portion in the context of the decision’s entire text and the governing law. The appellate court expressly stated it was granting Roberto “los alimentos que la ley le concede” (the support that the law grants him) and noted the Civil Code’s expansion of illegitimate children’s rights.
Under Article 290 of the Civil Code, support includes education until the recipient completes training for a profession, trade, or vocation, even beyond the age of majority. Therefore, the appellate court’s use of “or” (“o”) in its fallo indicated two alternative conditions for the cessation of support, not a single condition where majority automatically terminates the obligation if it occurs first. The obligation persists if the child, though a major, is still completing his education or training. Consequently, the respondent Judge’s order for continued support was a correct enforcement of the appellate decision as interpreted in light of substantive law. However, the Court noted that the obligation to furnish support ceases upon the obligor’s death under Article 300 of the Civil Code, a circumstance the trial court must consider in implementing its order.