G.R. No. 132344 - University of the East vs. Jader

On November 28, 1922, the Court of First Instance of Pampanga probated a document (Exhibit A) as the last will and testament of Dolores Coronel.
The will, executed on July 1, 1918, contains the following key provisions:

Dolores Coronel declared her intent to revoke all previous wills.
She ordered that her body be buried in conformity with her social standing.
She bequeathed all her movable and immovable properties, as well as her credits, to her nephew, Lorenzo Pecson, who is married to her niece, Angela Coronel.
Lorenzo Pecson was appointed as executor without bond, with a substitute executor, Victor Pecson, designated in the event he could not discharge his duties.
A detailed inventory of her properties was referenced in the will.

Dolores Coronel, not knowing how to write, had her name written by Vicente J. Francisco, under her express direction and in the presence of witnesses.
The will was executed in the presence of multiple attesting witnesses, whose signatures appear on every page of the document.

Lorenzo Pecson, the nephew of the testatrix and husband of Angela Coronel, filed the petition for probate.

A group of blood relatives and persons with familial claims – including Eriberto Coronel, Tito Coronel, Julian Gozum, Cirila Santiago, the widow of Macario Gozum with her three minor children, Hilarion, Geronimo and Maria Coronel (with her husband Eladio Gongco), Juana Bituin (widow of Hipolito Coronel with her three children), Rosario Coronel, Agustin Coronel, Filomeno Coronel, Casimiro Coronel, Alejo Coronel, Maria Coronel, Severina Coronel, Serapia Coronel, and Maria Juana de Ocampo (widow of Manuel Coronel), Dionisia Coronel and her husband Pantaleon Gunlao.

The document (Exhibit A) might not be a true representation of Dolores Coronel’s last will, suggesting her true intention was to distribute her estate among her blood relatives rather than solely to Lorenzo Pecson.
The attestation clause of the will was argued to be noncompliant with section 618 of the Code of Civil Procedure, as amended by Act No. 2645, due to a perceived failure to demonstrate that witnesses had signed in the proper manner (i.e., in the presence of each other and of the testatrix).

Six years before executing Exhibit A, a previous will (Exhibit B) had been made wherein Dolores Coronel had named Lorenzo Pecson as her sole heir.
The contents of Exhibit B suggested that although Lorenzo had been entrusted as an heir and executor, he was not necessarily intended to be the exclusive beneficiary of her property.

Upon the advice of Attorney Francisco, who was also the legal adviser of Dolores Coronel, the testatrix remade her will to align it with the new legal formalities required by Act No. 2645.
Testimonies from various witnesses—including Attorney Francisco, Pablo Bartolome, Norberto Paras, and others—provided evidence about the manner of execution and Dolores Coronel’s intentions.

Whether the probated will (Exhibit A) truly expresses the last and voluntary intention of Dolores Coronel in favor of Lorenzo Pecson.
Whether the exclusions of her blood relatives from the inheritance, as manifested in Exhibit A, were a product of her free testamentary discretion or resulted from extraneous or wrongful influence.

Whether the wording used in the attestation clause of the will conforms to the requirements of Section 618 of the Code of Civil Procedure (as amended by Act No. 2645).
Specifically, if the phrase “signed these presents in the presence of others and of the testatrix” adequately complies with the mandatory formalities regarding the witnesses signing in the presence both of the testatrix and one another.