292 Matabuena

Herein appellant’s brother Felix Matabuena donated a piece of lot to his common-law spouse, herein
appellee Petronila Cervantes. Felix and Petronila got married only in 1962 or six years after the deed
of donation was executed. Five months later, or September 13, 1962, Felix died. Thereafter,
appellant Cornelia Matabuena, by reason of being the only sister and nearest collateral relative of the
deceased, filed a claim over the property, by virtue of a an affidavit of self-adjudication executed by
her in 1962, had the land declared in her name and paid the estate and inheritance taxes thereon.
The lower court of Sorsogon declared that the donation was valid inasmuch as it was made at the
time when Felix and Petronila were not yet spouses, rendering Article 133 of the Civil Code
inapplicable.

Whether or not the ban on donation between spouses during a marriage applies to a common-law
relationship.

Supplying the legislative omission, the court ruled that the ban of donation between spouses applies
to a common-law relationship. However, the lack of validity of the donation of Felix Matabuena to
Petronila Cervantes does not necessarily result to plaintiff having exclusive rights to the disputed
property. Because Petronila and Felix Matabuena were legally married before Felix died, Petronila is
his widow. Hence, she is entitled to 1/2 of the property of the deceased. The other half would be given
to Felix Matabuena’s sister, Cornelia Matabuena

303 Beumer v Amores

Facts: Willem Beumer, a Dutch national, married Avelina Amores on March 29, 1980. Their marriage
was declared null by the RTC by reason of psychological incapacity. Willem thus filed for Dissolution
of Conjugal Partnership praying for distribution of the properties acquired during their marriage which
include 4 lots of land acquired through purchase and 2 lots by inheritance. RTC ruled that all parcels
of land be given to the respondent, tools, and equipment in favor of the petitioner and the two houses
on Lots 1 and 2142 as co-owned by the parties.

Issue: WON Willem has the right to claim reimbursement from the purchase of the real properties
subject to the dissolution proceedings

No. Firstly, foreigners may not own lands in the Philippines. However, there are no restrictions to the
ownership of buildings or structures on lands of foreigners. As such, the two houses are considered
co-owned by the parties. While admitting to have previously executed a joint affidavit that
respondent’s personal funds were used to purchase Lot 1, he likewise claimed that his personal
disability funds were used to acquire the same. The Court cannot, even on the grounds of equity,
grant reimbursement to petitioner given that he acquired no right whatsoever over the subject
properties by virtue of its unconstitutional purchase. A contract that violates the Constitution and the
law is null and void, vests no rights, creates no obligations and produces no legal effect at all.