Matabuena vs. Cervantes

The statutory prohibition against donations between spouses during marriage (Article 133 of the Civil Code) applies with equal force to donations between persons living together as husband and wife without the benefit of marriage, based on public policy considerations and the need to prevent undue influence in such relationships.

The case arose from a gap in the Civil Code, which explicitly prohibited donations between legally married spouses but was silent regarding donations between partners in a common-law relationship. The dispute centered on whether the policy behind the law—preventing the stronger party from exercising undue influence over the weaker party—should extend to irregular unions, thereby nullifying a land donation made by a man to his partner prior to their eventual marriage.

• Felix Matabuena owned a specific parcel of land.
• On February 20, 1956, Felix executed a Deed of Donation inter vivos transferring this land to Petronila Cervantes, which she accepted.
• At the time of the donation, Felix and Petronila were living together as husband and wife without the benefit of marriage (common-law relationship).
• Felix and Petronila subsequently married on March 28, 1962, six years after the donation.
• Felix Matabuena died intestate on September 13, 1962.
• Cornelia Matabuena, the sister of the deceased, executed an affidavit of self-adjudication in 1962, claiming to be the sole heir and asserting ownership over the land.
• Cornelia filed a complaint to nullify the donation, arguing it was void under the Civil Code provisions prohibiting donations between spouses.
• The parties stipulated these facts during the trial in the lower court.

• The donation made by the deceased to the defendant while they were living maritally without the benefit of marriage was void.
• The prohibition against donations between spouses under Article 133 of the Civil Code should extend to their relationship.
• As the sister and nearest collateral relative, the petitioner is entitled to the property.

• The donation was valid because it was executed in 1956, at a time when the donor and donee were not yet married.
• Article 133 of the Civil Code prohibits donations between "spouses," and strictly speaking, they did not become spouses until their marriage in 1962.

• Procedural Issues:
• N/A
• Substantive Issues:
• Whether the prohibition against donations between spouses during marriage (Article 133, Civil Code) applies to a donation made between common-law spouses living together without the benefit of marriage.

• Procedural:
• N/A
• Substantive:
• The Supreme Court reversed the lower court's decision, declaring the donation void. The Court reasoned that the policy of the law is to prevent undue and improper pressure and influence upon the donor, a prejudice deeply rooted in ancient law.
• The Court held that if the law prohibits donations between spouses to prevent one from despoiling the other through affection or pressure, there is every reason to apply the same policy to persons living together as husband and wife without nuptials, where the danger of undue influence may be even greater.
• While the donation was declared void, the Court ruled that the plaintiff (sister) is not the exclusive owner. Since the marriage legitimated the relationship prior to Felix's death, Petronila is his legal widow. Under Article 1001 of the Civil Code, the inheritance must be shared: one-half to the widow (Petronila) and one-half to the surviving sister (Cornelia).

• Prohibition on Donations Between Common-Law Spouses — The ban on donations between spouses during marriage (Article 133) extends to common-law relationships. The doctrine posits that the rationale for the ban—preventing undue influence and protecting the weaker spouse from being despoiled by the other—applies with equal or greater force to irregular unions.
• Spirit of the Law (Statutory Construction) — What is within the spirit of the law is as much a part of it as what is written. Courts must look beyond the literal language to the purpose and objective of the statute; ignoring the ban in common-law cases would nullify the law's policy of justice and right.

• "So long as marriage remains the cornerstone of our family law, reason and morality alike demand that the disabilities attached to marriage should likewise attach to concubinage."
• "It would be to indict the framers of the Civil Code for a failure to apply a laudable rule to a situation which in its essentials cannot be distinguished."
• "El espiritu que informa la ley debe ser la luz que ha de guiar a los tribunales en la aplicacion de sus disposiciones." (The spirit that informs the law must be the light that guides the courts in the application of its provisions).

• Buenaventura v. Bautista — A 1954 Court of Appeals decision cited as the primary authority. It was referenced because it unequivocally held that donations between common-law spouses are void as contrary to public policy, a view the Supreme Court adopted in this case.
• Yellow Taxi and Pasay Trans. Workers Union v. Manila Yellow Taxicab Co. — Cited to support the principle of statutory construction that the spirit of the law must prevail over a literal interpretation that leads to conclusions incompatible with the law's manifest object.

• Article 133, Civil Code — "Every donation between the spouses during the marriage shall be void." This was the central provision interpreted by the Court to include common-law relationships.
• Article 1001, Civil Code — "Should brothers and sisters or their children survive with the widow or widower, the latter shall be entitled to one-half of the inheritance and the brothers and sisters or their children to the other half." This article was applied to determine the final distribution of the property between the plaintiff and the defendant.