Appeal on Modification of Spousal and Child Support Due to Changed Financial Circumstances

In an appeal challenging a family law decision that modified spousal and child support obligations following separation, the court upheld the reduction of child support and annulment of spousal support based on changed financial circumstances. The appellate court reasoned that the threshold for establishing significant and permanent changes in the context of modifying a separation maintenance order (Art. 179 ZGB) is lower than for post-divorce support; specifically, temporary but extended short-time work warrants adjustment with a reservation for future increase, and given the parties' tight finances, even a relatively small income reduction, found to be permanent due to job change, constitutes a significant change justifying relief.