Case Summary (G.R. No. L-28771)
Factual Stipulation Before Trial
At the November 1965 trial, both parties agreed on these facts:
- Felix owned the disputed land.
- He donated it to Petronila on February 20, 1956, during their consensual cohabitation.
- They married on March 28, 1962.
- Felix died intestate on September 13, 1962.
- Cornelia thereafter executed an affidavit of self-adjudication, paid estate taxes, and claimed ownership.
Lower Court’s Ruling on Technical Marital Status
The trial court held that Article 133 did not apply because Felix and Petronila were not yet “spouses” in 1956. It deemed the donation valid, reasoning that the prohibition attaches only to donations made during a formal marriage.
Application of Civil Code and Jurisprudence
The Supreme Court reversed, relying on the 1954 Buenaventura v. Bautista decision, which interpreted the old Civil Code to void donations between de facto spouses. It underscored the policy against undue influence and mutual spoliation, grounded in Roman and Spanish legal authorities (Partidas and Pandects).
Policy and Moral Grounds Extending Prohibition
The Court emphasized that marriage remains the cornerstone of family law, and that concubinage often involves equal or greater risk of coercion. Invoking the maxim that the spirit of the law controls its literal text, the Court held that the prohibition’s underlying objectives—preventing improper pressure and unjust enrichment—demand its application to common-law unions.
Heirs’ Rights Upon Void Donation
Declaring the 1956 donation void, the Court clarified that Petronila, as lawfully wedded widow, still shared in the estate. Under Ar
...continue readingCase Syllabus (G.R. No. L-28771)
Facts of the Case
- Felix Matabuena, now deceased, owned a parcel of land and executed a Deed of Donation inter vivos in favor of Petronila Cervantes on February 20, 1956.
- At the time of the donation, Matabuena and Cervantes were living together as husband and wife without benefit of marriage.
- The parties later married on March 28, 1962, and Matabuena died intestate on September 13, 1962.
- Cornelia Matabuena, the only sister and nearest collateral relative of the deceased, claimed the property by self-adjudication and paid the estate and inheritance taxes.
Procedural History
- The trial court received a joint stipulation of facts by both parties on November 19, 1965, repeating the ownership, date of donation, common-law relationship, subsequent marriage, and death of Matabuena.
- On November 23, 1965, the lower court held the donation valid, reasoning that Article 133 of the Civil Code prohibits only donations between legally married spouses during marriage, and at the time of the deed, the parties were not yet married.
- Cornelia Matabuena appealed this decision to the Supreme Court of the Philippines.