Child support —whether governed by the Spanish Civil Code (CC) or by Book II of the Catalan Civil Code (CCC)— is one of the core obligations parents owe to their children. It is considered a matter of public policy and cannot be waived, particularly when children are minors, as it is directly tied to parental responsibility.

Once children reach adulthood, certain circumstances may justify ending child support. Common examples include the child becoming financially independent after entering the labor market, or situations where the parent–child relationship has completely broken down.

This article examines the scenarios in which child support may be terminated due to a lack of relationship between the parent and the adult child, as set out in Articles 152.4 CC and 237-13 CCC.

To terminate child support on this basis, the following conditions must be met:

  • There must be a complete and long-standing absence of any parent–child relationship, not just a temporary distancing.
  • The breakdown must be serious and persistent.
  • The lack of contact must be solely attributable to the child, with no reasonable justification, and without any fault on the parent’s side. The parents must have made genuine efforts to maintain or rebuild the relationship, which proved unsuccessful.

Each case must be assessed individually. Evidence plays a key role: statements from the parties, witness testimony, documents such as emails or WhatsApp messages, expert reports, and any previous actions taken (e.g., mediation processes, enforcement proceedings or attempts at supervised visitation). All evidence must clearly show that the legal requirements are met.

The Spanish Supreme Court, in Judgment 104/2019 (19 February), established the criteria for terminating child support due to a relationship breakdown. The rupture must be:

  1. serious and significant,
  2. clear and ongoing, and
  3. exclusively attributable to the child.

The Court also stressed that these criteria must be applied restrictively.

Terminating child support requires filing for a modification of measures under Article 775 of the Civil Procedure Act (LEC). Under LO 1/2025, an alternative dispute resolution procedure (MASC) must be attempted beforehand when the modification is contentious.

Relevant case law includes:

1) Judgments terminating child support due to a breakdown in the parent–child relationship:

  • Judgment of the Provincial Court of Barcelona, 15 March 2012.
  • Judgment of the Provincial Court of Granada, 26 May 2025.
  • Order of the Provincial Court of Castellón, 5 March 2025.
  • Judgment of the Provincial Court of Álava, 27 March 2024.
  • Judgment of the Provincial Court of Las Palmas, 17 January 2024.
  • Judgment of the Provincial Court of Tarragona, 15 November 2017.

 2) Judgments maintaining child support due to failure to meet the legal requirements:

  • Judgment of the Provincial Court of Zaragoza, 16 May 2025.
  • Judgment of the Provincial Court of the Balearic Islands, 29 May 2025.
  • Judgment of the Provincial Court of Barcelona, 30 April 2025.
  • Judgment of the Provincial Court of Jaén, 28 November 2024.
  • Judgment of the Provincial Court of Albacete, 13 March 2023.
  • Judgment of the Provincial Court of Cantabria, 15 May 20

Case law consistently highlights that the third requirement, the breakdown being solely attributable to the child— is often the most decisive. It must be clearly proven that the child unilaterally chose to sever the relationship and that the parent seeking termination did not contribute to the situation.

At addwill, our litigation team is available to provide further information and specialized legal guidance. You can reach us via the contact form.