Case Digest (G.R. No. 174489)
Facts:
The case involves a petition for review on certiorari filed by Antonio B. Baltazar, Sebastian M. Baltazar, Antonio L. Mangalindan, Rosie M. Mateo, Nenita A. Pacheco, Virgilio Regala, Jr., and Rafael Titco (collectively referred to as "petitioners") against Lorenzo Laxa (the "respondent"). The case originated from the Regional Trial Court (RTC) of Guagua, Pampanga, which rendered a decision on September 30, 2003, disallowing the probate of the notarial will of Paciencia Regala, executed on September 13, 1981. Paciencia, a 78-year-old spinster, bequeathed her properties to Lorenzo and his family, with whom she had a close relationship, having raised Lorenzo since his birth. After her death on January 4, 1996, Lorenzo filed a petition for probate of the will on April 27, 2000. The RTC initially allowed Lorenzo to present evidence, but the petitioners opposed the probate, claiming that Paciencia lacked testamentary capacity and that the will was executed under...
Case Digest (G.R. No. 174489)
Facts:
1. Execution of the Will:
Paciencia Regala, a 78-year-old spinster, executed her last will and testament on September 13, 1981, in the house of retired Judge Ernestino G. Limpin. The will, written in the Pampango dialect, was read to Paciencia twice. She signed the will in the presence of three instrumental witnesses: Dra. Maria Lioba A. Limpin, Francisco Garcia, and Faustino R. Mercado. Judge Limpin acted as the notary public.
2. Bequests in the Will:
Paciencia, who had no children, siblings, or brothers, bequeathed all her properties to her nephew Lorenzo Laxa, his wife Corazon, and their children. The properties included fishponds and other assets.
3. Custody of the Will:
The will remained in the custody of Judge Limpin after its execution. Paciencia left for the United States six days later and lived with Lorenzo and his family until her death on January 4, 1996.
4. Probate Proceedings:
On April 27, 2000, Lorenzo filed a petition for the probate of Paciencia’s will in the Regional Trial Court (RTC) of Guagua, Pampanga. Initially, there was no opposition, but Antonio Baltazar and other relatives later filed an opposition, claiming that Paciencia lacked testamentary capacity and that the properties belonged to Nicomeda Regala Mangalindan, Antonio’s predecessor-in-interest.
5. Testimonies and Evidence:
- Dra. Limpin testified that Paciencia was of sound mind when she executed the will.
- Rosie Mateo, a relative, claimed that Paciencia was forgetful and did not understand the nature of the will.
- Antonio Baltazar alleged that Paciencia did not intend to sign the will and left it unsigned.
Issue:
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Ruling:
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Ratio:
- Formal Requirements of a Will: The will complied with Articles 805 and 806 of the Civil Code, which require the testator and witnesses to sign in the presence of each other and a notary public.
- Presumption of Sound Mind: Under Article 800 of the Civil Code, every person is presumed to be of sound mind unless proven otherwise. The petitioners failed to provide substantial evidence to rebut this presumption.
- Forgetfulness vs. Mental Incapacity: Forgetfulness does not render a person mentally unsound or incapable of executing a will. Paciencia’s awareness of her properties and the nature of the testamentary act was established.
- Burden of Proof: The burden to prove that Paciencia was of unsound mind or acted under duress lies with the oppositors. The petitioners failed to meet this burden.
- Primacy of the Testator’s Intent: The state has a duty to give effect to the testator’s wishes, provided the will is legally valid. The relationship between Paciencia and Lorenzo supported the authenticity of the will.