Case Digest (G.R. No. L-28771) Core Legal Reasoning Model
Facts:
In CORNELIA MATABUENA v. PETRONILA CERVANTES (148 Phil. 295, G.R. No. L-28771, March 31, 1971), Cornelia Matabuena, sister and sole collateral heir of the late Felix Matabuena, sued Petronila Cervantes to annul an inter vivos donation executed by Felix on February 20, 1956. At that time, Felix and Petronila were living together in a common-law relationship and did not solemnize their marriage until March 28, 1962. Upon Felix’s death on September 13, 1962, Cornelia filed an affidavit of self-adjudication and had the disputed parcel declared in her name, alleging that the donation to Petronila was void under Article 133 of the Civil Code. The trial court, by its decision of November 23, 1965, dismissed Cornelia’s complaint, holding that the ban on donations between spouses during marriage did not apply to common-law partners and that the donation was valid because it was made before the parties’ nuptials. Cornelia then appealed to the Supreme Court.
Issues:
- Under Article 133 of
...
Case Digest (G.R. No. L-28771) Expanded Legal Reasoning Model
Facts:
- Parties and Relationship
- Cornelia Matabuena (plaintiff-appellant) is the sister and nearest collateral relative of the deceased, Felix Matabuena.
- Petronila Cervantes (defendant-appellee) lived with Felix in a common-law relationship beginning before 1956 and married him on March 28, 1962.
- Donation, Death, and Stipulation
- On February 20, 1956, Felix executed a Deed of Donation inter vivos conveying the disputed parcel of land to Cervantes, which she accepted.
- Felix and Cervantes married on March 28, 1962; Felix died intestate on September 13, 1962.
- Matabuena claimed the property as the only sister and nearest heir, executing an affidavit of self-adjudication in 1962 and paying estate taxes.
- Procedural History
- In the trial court, the parties stipulated to the above facts and Matabuena’s allegation that the donation was void under Article 133 of the Civil Code.
- The trial court held the donation valid, reasoning it was made before marriage, and dismissed the complaint.
- Matabuena appealed to the Supreme Court, raising the novel question of extending the Article 133 prohibition to common-law relationships.
Issues:
- Whether the prohibition against donations between spouses during marriage under Article 133 of the Civil Code applies to partners in a common-law (concubinage) relationship.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)