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...

Facts:

Background and Execution of the Will

• Paciencia Regala, a 78-year-old spinster with no children or siblings, executed her last will and testament on September 13, 1981, in Pampanga.
• The will was created in the Pampango dialect and bore the title “Tauli Nang Bilin o Testamento Miss Paciencia Regala.”
• It was executed at the residence of retired Judge Ernestino G. Limpin, who acted as notary public.
• Paciencia read the will twice and confirmed that it was indeed her last testament before affixing her signature on page 3 and along the left margins of pages 1, 2, and 4.
• The will was attested by three instrumental witnesses: Dra. Maria Lioba A. Limpin, Francisco Garcia, and Faustino R. Mercado, who each signed below the attestation clause and on the left margin of the designated pages.

Relationship and Personal Circumstances

• Although childless, Paciencia maintained a close and recognized familial bond with Lorenzo R. Laxa, her nephew, whom she treated as her own son.
• Paciencia resided with Lorenzo’s family in Sasmuan, Pampanga before departing for the United States on September 19, 1981, where she lived with the family until her death on January 4, 1996.
• The will remained in the custody of Judge Limpin until it was presented for probate proceedings.

Probate Proceedings and Opposition

• On April 27, 2000, Lorenzo filed a petition with the RTC of Guagua, Pampanga (Special Proceedings No. G-1186) for the probate of the will and for Letters of Administration in his favor.
• With no initial opposition, the RTC allowed Lorenzo to present evidence, including testimony from Dra. Limpin, Lorenzo, and Monico Mercado.
• Petitioners, led by Antonio Baltazar and joined by several others, subsequently opposed the probate on several grounds:
• They claimed that the properties bequeathed in the will actually belonged to Nicomeda Regala Mangalindan, a predecessor-in-interest.
• They argued that the will was null and void because Paciencia had not acquired proper title to the properties before her death pursuant to Article 1049, paragraph 3 of the Civil Code.
• They contended that Paciencia was of unsound mind at the time of execution, alleging forgetfulness, duress, undue influence, and even forged or tricked signature as evidence against the validity of the will.
• Testimonies in opposition included:
• Rosie testified that Paciencia displayed signs of forgetfulness (“magulyana” behavior) and recounted a conversation where Paciencia appeared reluctant about signing the documents.
• Antonio testified that Paciencia expressed reservations regarding the content of the documents and left them unsigned, later turning them over to Faustino.

Evidentiary Testimonies and Explanations

• Dra. Limpin testified to witnessing Paciencia sign the will properly and confirmed the presence of all necessary signatures, including that of her father (the acting notary).
• Lorenzo testified about his longstanding familial relationship with Paciencia, asserting she was of sound mind and that the will was executed without coercion – noting he was not even present in the country at the time.
• Explanations were provided regarding the absence of certain witnesses:
• Francisco died on May 21, 2000.
• Faustino was unable to fully testify due to severe health issues (brain damage and inability to speak).
• Judge Limpin (through Dra. Limpin’s testimony) was incapacitated following a stroke and subsequent brain surgery, explaining his absence from court.
• Despite allegations by petitioners regarding Paciencia’s alleged incapacity and undue influence, no substantial or corroborative evidence was presented to prove these claims.

Issue:

Issue on Procedural Compliance and Attendance of Witnesses

• Whether the failure to produce all attesting witnesses (due to death, health issues, or incapacity) violated Section 11, Rule 76 of the Rules of Court, and whether such non-attendance precluded the probate of the will.

Issue on the Testator’s Mental Capacity

• Whether evidence showing Paciencia’s occasional forgetfulness (being “magulyana”) is sufficient to prove that she lacked testamentary capacity at the time of execution.
• Whether the allegations of duress, undue influence, and fraud regarding the signing of the will, based primarily on isolated eyewitness accounts, overcome the presumption of sound mind.

Issue on the Authenticity and Due Execution of the Will

• Whether the will complies with the statutory requirements under Articles 805 and 806 of the Civil Code and Rule 75, Section 1 of the Rules of Court, ensuring its extrinsic validity.
• Whether the state’s duty to give effect to the testator’s expressed intent should prevail despite petitioners’ unsubstantiated allegations.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)