Facts:

• On June 26, 2006, Margie Santos Mitra filed a petition for the probate of the notarial will of Remedios Legaspi y Reyes before the RTC of Caloocan City, Branch 128.
• Mitra claimed to be the de facto adopted daughter of Legaspi, who passed away on December 22, 2004, in Caloocan City.
• Legaspi's will named Mitra, Orlando Castro, Perpetua Sablan Guevarra, and Remigio Legaspi Sablan as heirs, legatees, and devisees, and appointed Mary Ann Castro as the executor.
• The will was contested by Perpetua L. Sablan-Guevarra and Remegio L. Sablan, who claimed to be Legaspi's legal heirs.
• Respondents argued that the will was not executed in accordance with legal formalities, specifically noting the last page containing the Acknowledgement was not signed by Legaspi and the instrumental witnesses, and the attestation clause did not state the number of pages of the will.
• They also alleged undue influence and improper pressure on Legaspi.
• The RTC admitted the will to probate, finding it duly executed and dismissing the allegations of undue influence due to lack of evidence.
• Respondents appealed to the CA, which reversed the RTC's decision, citing non-compliance with the formalities required by law, particularly the lack of signatures on each page and the omission of the number of pages in the attestation clause.
• The CA also denied the respondents' motion for reconsideration for being filed a day late.

Issue:

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Ruling:

• The Supreme Court ruled in favor of the petitioner, reversing the CA's decision and reinstating the RTC's decision to admit the will to probate.
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Ratio:

• The Supreme Court emphasized the importance of procedural rules but also highlighted that these rules should not hinder the demands of substantial justice.
• The Court noted that the CA's strict application of procedural rules would result in the unjust invalidation of Legaspi's will.
• The Court found that the original copy of the will, as opposed to the altered photocopy submi...continue reading