Domingo v.

CA
FACTS:

Paulina Rigonan owned three parcels of land located at Batac and Espiritu, Ilocos
Norte, including a house and warehouse on one parcel. She allegedly sold them
to Felipe and Concepcion Rigonan, who claim to be her relatives. Petitioners Domingo,
Mangabat and Capalungan who claim to be Paulina’s closest surviving relatives, allegedly took
possession of the property by means of stealth, force and intimidation and refused to vacate the
same. Felipe Rigonan filed a complaint for reinvindicacion against petitioners in the RTC of
Batac, Ilocos Norte, alleging their ownership of the land through the deep of sale executed by
Paulina Rigonan and since then have been in continuous possession of the properties and
introduced permanent improvements thereon. According to the petitioners, the deed of absolute
sale was void for being spurious since they inherited the three lots and the permanent
improvements as nearest surviving kin within the fifth degree of consanguinity to Paulina. The
RTC ruled in the petitioner’s favor, declaring them the lawful owners of the contested land. The
Court of Appeals reversed the trial court’s decision and ordered the petitioners to vacate the
subject properties and surrender possession thereof.

Issues:
(1) Whether or not private respondents sufficiently established the existence and due execution
of the Deed of Absolute and Irrevocable Sale of Real Property.
(2) Whether or not Paulina Rigonan was competent to enter into said contract.

Ruling:
Paulina Rigonan was in continuous possession of the property in this case, throwing
an inverse implication and serious doubt on the due execution of the deed of sale. The same
parcels of land involved in the alleged sale were still included in the will subsequently executed
by Paulina and notarized by Atty. Tagatag. These circumstances, taken together, militate against
unguarded acceptance of the due execution and genuineness of the alleged deed of sale.
At the time of the execution of the alleged contract, Paulina Rigonan was already of advanced
age and senile, attested by the testimony that she played with her waste and urinated in bed. She
died an octogenarian barely a year when the deed was allegedly executed. The general rule is
that a person is not incompetent to contract merely because of advance years or by reason of
physical infirmities. However, when such age or infirmities have impaired the mental faculties so
as to prevent the person from properly, intelligently and firmly protecting her property rights
when she is undeniably incapacitated.
The decision of the Court of Appeals is reversed and set aside and the decision of the Batac
RTC is reinstated.

Medina v. Collector of Internal Revenue

FACTS:
Antonio Medina and Antonia Rodriguez married in 1944 without any property. Antonio later
acquired forest concessions in Isabela. In 1949, Antonia engaged in lumber business. From 1949
to 1952, Antonio sold all his logs to Antonia. Antonia in turn sold the products in Manila through
an agent. Upon assessment of their taxes, the Collector of Internal Revenue considered the sale
from Antonio to Antonia as null and void, thus, an additional tax of about 4,553.54 was assessed.
The spouses protested the assessment claiming that they had a prenuptial agreement pf complete
separation of properties.

Issue: Whether or not the sale between the spouses is valid

Held:
No. The validity of the prenuptial agreement was declared by the court null because of material
inconsistencies a) the prenuptial agreement was said to be executed 3 months before the
marriage; b) the spouses did not have any property before the marriage which would compel
them into entering into the agreement c) they did not act in accordance to the said agreement.

The sale from Antonio to Antonia was null because such is expressly prohibited in Article 1490
of the Civil Code.

Matabuena v. Cervantes
FACTS:
Felix Matabuena cohabitated with Respondent. During this period, 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: Whether or not 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 dece
ased 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.