Matabuena v. CervantesCase No. 172G.R. No. L-28771 (March 31, 1971)Chapter IV, Page 143, Footnote No.69FACTS:Felix Matabuena cohabitated with Respondent. During this period, FelixMatabuena donated to Respondent a parcel of land. Later the two were married.After the death of Felix Matabuena, his sister, Petitioner, sought the nullification of thedonation citing Art.133 of the Civil Code “Every donation between the spousesduring the marriage shall be void.”The trial court ruled that this case was not covered by the prohibition becausethe donation was made at the time the deceased and Respondent were not yetmarried and were simply cohabitating.ISSUE:W/N the prohibition applies to donations between live-in partners.HELD:Yes. It is a fundamental principle in statutory construction that what is withinthe spirit of the law is as much a part of the law as what is written. Since the reason forthe ban on donations between spouses during the marriage is to prevent thepossibility of undue influence and improper pressure being exerted by one spouse onthe other, there is no reason why this prohibition shall not apply also to common-lawrelationships.The court, however, said that the lack of the donation made by thedeceased to Respondent does not necessarily mean that the Petitioner will haveexclusive rights to the disputed property because the relationship between Felix andRespondent were legitimated by marriage.LATIN MAXIM:6c, 9a, 9c