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Matabuena v. Cenrantes (1971)

Facts: Felix cohabitated with the respoooent without the benefit of marriage. Dwing this period, he donated to
respondent a parcel of lard. They were subsequently married. After the death of Felix, his sister, petitioner herein,
so~ht the nullification of the donation citing Art.133 of the Civil Code tlIlt "Every donation between tOO spouses
during the marriage shall be void." The trial court ~ that this case was not covered by tOO prohibition because the
donation was made at tOO time the deceased and respolKieDt were not yet married aOO were simply cohabitating.
Issue: WON the prohibition applies to donations in common-law marriages?
Held/Ratio: Yes. It is a fundamental pritK:iple in statutory construction that what is within the spirit of the law is as
much a part of tre law as what is written. Since the reason for the ban on donations between spouses during the
marriage is to prevent the possibility of w:ldue influeJK:e aOO improper pressure being exerted by one ~use on tre
other, there is no reason why this prohibition shall mt apply also to common-mw relationships. The court, however,
said that the lack of the donation made by the deceased to respoooent does mt JKJCessarily mean that the petitioner
will have exclusive rights to the disputed property because the relationship between Felix and respondent were
legitimated by marriage.
Bienvenido v. CA 0994)
Facts: Aurelio Camacho married Consejo on 1942. On 1962, with the first marriage being dissolved, he married
respondent Luisita. In 1967, Aurelio met petitioner Nenita, woo had been estranged from her husband. They lived
together until Aurelio's death on May 1988. Prior to hifI death, or on 1982, Aurelio bought the apartment they
stayed in with the TCT being issued in his name. On 1984, Aurelio executed a Deed of Sale in favor of Nenita
involving the subject property, aIxi tlK: TCT was consequently issued in ~ name.
After Aw-elio's death. Luisita claimed oWJx:rship of the house am ~t where Nenita had been living in. She
filed a case in tlK: RTC for tlK: annulment oftlK: sale oftlK: property to Nenita, a~ging that it was executed in fiaud
of her as the legitimate wife. Nenita claimed the property was purchased tl1l'ough their joint fuIMls which tlx:y
accumulated dlulng their cohabitation for 14 years and in the alternative, that she was a purcmser in good faith.
Issue: WON the marriage bet Luisita and AtU'elio is valid and, therefore, the sale of the property is void?
Held/Ratio: NO, petitioner showed that during the 2nd m81Tiage, the I It marriage was still subsisting. Therefore, it is
respondent's burden to prove otherwise which she failed to do Ig;), The alleged 7-year period a~ cannot be
invoked since it was Aw-elio who left his first wife. What applies to this case is ~ general rule that since Aw-elio
contracted a 2nd marriage while his 1- was still subsisting, his 2nd marriage is void for being bigamom. As such,
there can be no conjugal partnership between Luisita and Aurelio. An action for nullity of donations in this case can
only be brought by the innocent spouse, Consejo.
As a result, until otherwise proven, the validity of the sale to Nenita is presumed as evidenced by the deed
of sale and by the TCT. While the property was acquired during Aw-eoo's and Nenita's long period combitation,
there is nothing to show that Nenita knew Aurelio was married.
Sumbad v. CA (1999)
Facts: After the death of his wife Agata, George Tait combited with Maria to whom he donated a parcel of
unregistered land in Sum-at (Sum-at property). After George died, Maria sold lots iocluded w/in the Sum-at property
in favor of~ private respondents. They pW"chased ~ k>ts based on a Tax Declaration which showed Maria as the
o~r of the property and planted different fruit trees and plants on the k>t. After Maria died, petitiooors ocought an
action for quieting of title, nullification of deeds of sale, and recovery of possession wi damages against private
respondents, alleging tmt they are children aOO compulsory heirs of George am Agata. Tooy claim that the
proceeds to purchase tl.: Sum-at property was from the sale by George of the Otucan property conjugally owned by
their parents. Consequently, they argue that the deeds of sale are null am void am that the deed of donation was
forged. Meanwhile, private resporxlents claim to re purchasers in good faith, basing their owoorship on the Tax
Declaration in ~ name of Maria.
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