PELAYO v.

LAURON
G.R. No. L-4089
January 12, 1909

Ponente: TORRES, J.

FACTS:

The petitioner, Pelayo, a doctor, gave medical assistance during the delivery of the daughter-
in-law of the defendants. The value of services given by him amounted to P500.00, which
the defendants declined to pay without reasons. Herewith, the plaintiff implored that the
judgment be entered in his favor as against the defendants for the sum of P500.00 and
added costs. The RTC cleared the defendant, with CA confirming the said ruling.

ISSUE:

Are the defendants obliged to pay the petitioner for the medical assistance rendered to their
daughter-in-law?

Ruling:

No. According to Article 1157 of the New Civil Code, obligations are created by law, by
contracts, by quasi-contracts, by illicit acts and omissions or by those which any kind of fault
or negligence occurs. Obligations arising from law are not presumed. Those expressly
determined in the Civil Code or in a special law and others are the only demandable ones.

The delivery of medical assistance in case of illness is one of the mutual obligations by which
the spouses are bound by way of mutual support as provided by the law or the Civil Code.
Subsequently, the obligation to pay the plaintiff for the medical assistance given to the
defendants’ daughter-in-law is an inherent responsibility of the husband. It is especially
established by the law that the obligation of the husband to provide his wife the necessary
services of a physician at such critical moments.