G.R. No. L-3272-73 - Gonzales vs. De Carungcong

Case Digest (G.R. No. L-3272-73)
Expanded Legal Reasoning Model

Facts:

Background of the Testatrix and the Estate

On November 27, 1948, Manuela Ibarra Vda. de Gonzales, aged about seventy-eight, died leaving behind an estate estimated at PHP150,000.
The testatrix left five children: Alejandro Gonzales, Jr., Manuel Gonzales, Leopoldo Gonzales, Manolita Gonzales de Carungcong, and Juan Gonzales.

Probate Proceedings and Wills Filed

On December 22, 1948, Manuel Gonzales filed a petition (Special Proceeding No. 837) in the Court of First Instance of Rizal for the probate of an alleged will executed on November 16, 1942 (referred to as Exhibit BManuel Gonzales), which purportedly devised the greater portion of the estate to him, while preserving the legitimes of the other children.
On December 31, 1948, Manolita G. de Carungcong filed her own petition (Special Proceeding No. 838) for the probate of another alleged will executed on May 5, 1945 (referred to as Exhibit 1Manolita G. Carungcong), proposing to leave the greater bulk of the estate to herself, again without impairing the legitimes of the other children.

Opposition and Intervention by Other Heirs

Alejandro Gonzales, Jr. opposed the probate proceedings by claiming that both wills had been revoked by an instrument executed on November 18, 1948 (Exhibit 2Alejandro and Juan Gonzales).
With the exception of Leopoldo Gonzales, all of the testatrix’s children filed mutual oppositions in one way or another against the wills and related instruments to defend their respective positions.

Trial Court’s Decision

The Court of First Instance rendered a decision with three key findings:

Exhibit BManuel Gonzales, though validly executed in 1942, was revoked by Exhibit 1Manolita G. Carungcong in line with Section 623 of the Code of Civil Procedure.
Exhibit 2Alejandro and Juan Gonzales, executed without the requisite knowledge and testamentary capacity of the testatrix and contrary to Section 618 of the Code of Civil Procedure, was declared null and void.
Exhibit 1Manolita G. Carungcong, having been executed according to law, was declared the true and last will and testament of the deceased, and it was admitted to probate.

Details of the Will Executed on May 5, 1945 (Exhibit 1Manolita G. Carungcong)

The will comprised seven pages (or “dahon/pagina”) with consecutive numbering, each page bearing the testatrix’s genuine signature, along with the signatures of the instrumental witnesses.
The text includes an attestation clause wherein the testatrix signed in the presence of three witnesses—Bienvenido de los Reyes, Tahimik T. Sayoc, and Luis Gaerlan—thereby ratifying the authenticity and due execution of the will.

Contentions on the Attestation Clause of the Will

Appellants contended that the will did not contain a valid attestation clause because:

It appeared that the attestation was made by the testatrix rather than by the witnesses.
The clause did not clearly state the number of sheets or pages constituting the will.

The trial court, referencing previous rulings (e.g., Valentina Cuevas vs. Pilar Achacoso and Aldaba vs. Roque), held that the attestation clause, as integrated into the body of the will by the testatrix herself and signed by all instrumental witnesses, sufficiently complied with legal requirements.

The Disputed Instrument of Revocation Executed on November 18, 1948

This instrument purportedly declared that the testatrix released any previously expressed testamentary intentions in any earlier wills.
The document was executed when the testatrix was allegedly in a comatose state, as testified by her family physician, Dr. Jose C. Leveriza, who observed symptoms that included aphasia, unconsciousness, and paralysis.
The instrument was prepared by Jose Padilla, with testimony indicating delays and poor excuses regarding its preparation—even as early as May 1948—raising doubts about its promptness and conformity to the testatrix’s wishes.

Testimony on the Testatrix’s Physical and Mental Condition

Dr. Jose C. Leveriza testified that:

The testatrix had suffered from hypertension for over ten years and experienced a marked deterioration in her mental and physical condition before her death.
On November 14, 1948, she exhibited aphasia and was subsequently admitted to the hospital on November 15.
By November 18, 1948, she was in a comatose state, unable to speak or understand, with unilateral paralysis, thereby compromising her capacity to execute any legal instrument meaningfully.

The testimony was corroborated by details regarding the progression of her illness, from aphasia to complete unconsciousness, culminating in pneumonia and later death on November 27, 1948.

Additional Considerations on the Execution of the Revocation Instrument

Testimony from Jose Padilla and others indicated that the instrument was executed without the active participation or clear understanding of the testatrix.
The absence of proper attestation by the witnesses, and the fact that no meaningful confirmation was sought from the testatrix regarding the extent of the revocation, further undermined its validity.

Issues:

Validity of the Attestation Clause in the Will Executed on May 5, 1945

Whether the attestation clause, as incorporated in the body of the will and signed by the testatrix and her witnesses, fulfills the legal requirement notwithstanding its apparent deviation from the usual form.

Validity of the Instrument of Revocation Executed on November 18, 1948

Whether the instrument revoking earlier wills is valid in view of the testatrix’s mental and physical incapacity at the time of its execution.
Whether the apparent delays and the manner of executing the revocation, coupled with the lack of proper attestation, negate the effectiveness of the revocation.

Impact on Multiple Wills Filed

How the revocation of the 1942 will (Exhibit BManuel Gonzales) and the standing of the 1945 will (Exhibit 1Manolita G. Carungcong) are affected by the legal arguments and factual circumstances surrounding the revocation instrument.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. L-3272-73) Core Legal Reasoning Model Expanded

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Case Digest (G.R. No. L-3272-73) Expanded Legal Reasoning Model

Facts:

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Doctrine:

Case Digest (G.R. No. L-3272-73)
Core Legal Reasoning Model

Expanded

Case Digest (G.R. No. L-3272-73)
Expanded Legal Reasoning Model