Maria Quintana v. Gelasio Lerma

Summary

This 1913 Supreme Court case involved a wife's action against her husband for monthly support under a separation agreement. The spouses had entered into a written agreement in 1905 whereby the husband undertook to pay P20 monthly support. The trial court ruled for the wife and struck the husband's adultery defense, reasoning that adultery is not a ground for cessation of support under Article 152 of the Civil Code. The Supreme Court reversed, holding that while the separation agreement was void under Article 1432 requiring judicial decree for property separation, the wife retained her right to support under the Civil Code. Significantly, the Court ruled that adultery constitutes a valid defense to support claims if properly proved, remanding the case for new trial to allow this defense.