Case Digest (G.R. No. 174489) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 174489, April 7, 2012, the Supreme Court resolved a petition by Antonio B. Baltazar, et al. (petitioners) to set aside the Court of Appeals’ grant of probate to the notarial will of Paciencia Regala, a 78-year-old spinster, executed on September 13, 1981, at the residence of retired Judge Ernestino G. Limpin in Pampanga. Witnesses Dra. Maria Lioba A. Limpin, Francisco Garcia, and Faustino R. Mercado attested the document, in which Paciencia bequeathed all her real and personal properties to her nephew Lorenzo R. Laxa, his wife Corazon, and their minor children, in consideration of services rendered to her. Six days later, Paciencia departed for the United States to live with Lorenzo’s family, where she remained until her death on January 4, 1996. Lorenzo filed for probate on April 27, 2000, with the Regional Trial Court of Guagua, Pampanga (RTC Branch 52). After publication, Lorenzo presented evidence but was opposed by Antonio and seven co-oppositors, who challenged Case Digest (G.R. No. 174489) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Testator and Execution of the Will
- Paciencia Regala, a 78-year-old spinster, executed a notarial will in Pampango dialect on September 13, 1981, at retired Judge Ernestino G. Limpin’s residence.
- The will was read twice to her; she signed at the end of page 3 and on the left margins of pages 1, 2, and 4.
- Instrumental witnesses Dra. Maria Lioba A. Limpin, Francisco Garcia, and Faustino R. Mercado attested and signed in her presence and that of one another; Judge Limpin notarized.
- Paciencia, childless and without siblings, bequeathed all properties to her nephew Lorenzo R. Laxa, his wife Corazon F. Laxa, and their children, with instructions for masses and compliance with the wishes of a deceased relative.
- Post-Execution Events and Initial Probate Petition
- Six days after execution, Paciencia left for the USA and resided with Lorenzo’s family until her death on January 4, 1996; the will remained with Judge Limpin.
- On April 27, 2000, Lorenzo filed a petition for probate (SP Proc. No. G-1186) in the RTC of Guagua, Pampanga; no opposition appeared after publication; RTC set hearings.
- Opposition and Trial Court Ruling
- Antonio Baltazar and others filed oppositions on grounds that the properties were not titled to Paciencia, Lorenzo was disqualified as administrator (U.S. resident), and Paciencia lacked testamentary capacity, was unduly influenced, or subject to fraud.
- RTC, after testimony from witnesses for both sides—including Dra. Limpin, Lorenzo, Monico Mercado, Rosie Mateo, and Antonio Baltazar—denied probate on September 30, 2003, finding Paciencia “magulyan” (forgetful) and mentally unfit.
- Court of Appeals Reversal
- On June 15, 2006, the CA reversed the RTC, granted probate, holding that forgetfulness does not negate testamentary capacity, the presumption of sound mind stood unrebutted, and formalities complied with.
- CA denied reconsideration on August 31, 2006.
Issues:
- Whether the CA erred in admitting the will for probate despite alleged non-compliance with Section 11, Rule 76 of the Rules of Court.
- Whether petitioners proved that Paciencia was not of sound and disposing mind at execution.
- Whether evidence sufficed to establish undue influence, fraud, or duress in procuring the will.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)