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Case Digest: Canonizado vs. Benitez, G.R. Nos. L-49315 and L-60966


Canonizado vs. Benitez

G.R. Nos. L-49315 and L-60966, February 20, 1984

Subject: Obligations and Contracts

FACTS

After their separation, the wife, Bernarda Canonizado, filed an action for support against her husband, Cesar Canonizado, in 1956. The trial court granted the wife's claim for support for their minor child but denied her claim for support for herself on the ground that she was gainfully employed. The wife appealed the decision to the Supreme Court, which reversed and remanded the case to the trial court for reconsideration.

On remand, the trial court modified its decision and granted the wife's claim for support for herself in the amount of P100.00 per month. The husband appealed the decision to the Court of Appeals, which affirmed the decision of the trial court. The husband then filed a petition for certiorari with the Supreme Court, but the petition was denied.

ISSUE

Whether or not the trial court erred in granting the wife’s claim for support.

RULING

No. The Supreme Court held that the trial court did not err in granting the wife's claim for support. A wife is entitled to receive support from her husband even if she is gainfully employed. The husband's duty to support his wife is not based on her need, but on his ability to support her. The right of a wife to receive support from her husband is not extinguished by the fact that she is gainfully employed.

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