FACTS:Felix Matabuena cohabitated with Respondent.

During this perio

d, Felix Matabuena 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 the donation citing Art.133 of the Civil Code
“Every donation between the spouses during the marriage shall be void.”
The trial court ruled that this case was not covered by the prohibition
because the donation was made at the time the deceased and Respondent
were not yet married 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 within the spirit of the law is as much a part of the law as what is written.
Since the reason
for the ban on donations between spouses during the marriage is to
prevent the possibility of undue influence and improper pressure being
exerted by one spouse on the other, there is no reason why this prohibition
shall not apply also to common law relationships.
The court, however, said that the lack of the donation made by the d
eceased to Respondent does not necessarily mean that the
Petitioner will have exclusive rights to the disputed property because the
relationship between Felix and Respondent were legitimated by marriage.