G.R. No. 232131 - Ifurung vs. Carpio-Morales

Testatrix and Will Execution
Natividad K. Kalaw, 63 years old, single, resident of Lipa City, executed a holographic will on December 24, 1968.
The will provided for her burial in the Lipa City Catholic Church, the erection of a monument at her expense, the bequest of all her real and personal property, and the appointment of her brother, Gregorio K. Kalaw, as sole executrix, bond-exempt.
The instrument as first written named her sister, Rosa K. Kalaw, as sole heir before insertions and cancellations were made.

Judicial Proceedings
September 1, 1971: Gregorio filed a petition for probate of the holographic will before the Court of First Instance of Batangas, Branch VI.
November 10, 1971: Rosa opposed probate, alleging that interlineations and alterations were not authenticated by the testatrix’s full signature as required by Article 814 of the Civil Code.
The National Bureau of Investigation reported that the handwriting, signature, insertions, and initials were all in the testatrix’s hand.
September 3, 1973: Trial court denied probate, holding that the alterations were not authenticated by the full signature and thus the will failed Article 814.
November 2, 1973: Reconsideration was denied on the ground that Article 814 is clear and mandatory.
Rosa filed a petition for review on certiorari before the Supreme Court, raising the sole legal question of whether the original unaltered text should be probated.

Whether a holographic will bearing insertions, erasures, and cancellations not authenticated by the testatrix’s full signature may be admitted to probate.
Whether, if the altered holographic will is void, the original unaltered provisions naming Rosa as sole heir should be given effect.