G.R. No. 95329 - Revilla vs. Court of Appeals

Don Cayetano Revilla, a bachelor without issue or surviving ascendants, executed his first last will and testament on January 28, 1978, bequeathing all his properties to his nine nephews and nieces, including petitioner Heracio Revilla.
The first will was duly probated on March 21, 1980 in Special Proceeding No. 128828 before the Court of First Instance of Manila.
A fire on November 19, 1981 destroyed the City Hall of Manila, including the records of the probate proceedings. Subsequently, a petition for reconstitution of the records was filed and granted after proper hearings that included Don Cayetano’s testimony.

Don Cayetano Revilla owned valuable real properties in Manila and Bulacan, including two parcels of land with buildings on Calle Azcarraga (now C.M. Recto Street) and six parcels in San Miguel, Bulacan.
Detailed descriptions and assessed values were provided for each property through their respective Transfer Certificates of Title (TCT Nos. 170750-ind., 170751-ind., T-192136, T-192137, T-22049, 22263, T-242301) and other documents such as cemetery lots.
The total estimated value of these properties approximated P30 million.

On November 19, 1986, Heracio Revilla, the eldest nephew, filed a petition for probate of a second will allegedly executed on September 13, 1982, purporting to name him as the sole heir and executor.
The second will was opposed by his eight siblings (the private respondents) who contended that:

The existence and probate of the first will were clear since the document had not been revoked.
The alleged second will was not executed in accordance with the law; its signature did not match Don Cayetano’s usual handwriting.
At the time of its alleged execution, Don Cayetano was either of unsound mind or being manipulated, rendering him vulnerable to undue influence.
The second will was procured under allegations of duress, fear, fraud, and improper influence on behalf of the petitioner.

Further, the respondents challenged Heracio’s appointment as executor given the heel of an allegedly void will.

Initially, after due hearings in the trial court in Special Proceeding No. 86-38444, the court disallowed the second will and dismissed the case with costs against Heracio Revilla.
The Court of Appeals later affirmed the trial court’s decision in CA-G.R. CV No. 18190 (September 19, 1990).
A petition for review was subsequently filed by Heracio under Rule 45 of the Rules of Court.
After an initial denial of the petition for review in November 1990 for addressing only factual issues, a motion for reconsideration was granted. However, further deliberation convinced the appellate court and ultimately the Supreme Court that the decision to disallow the second will was proper.

During the reconstitution proceedings of the first will on November 27, 1982, Don Cayetano testifed that he was unaware of any second will and expressly confirmed that his first will was his “true and only will.”
Don Cayetano’s testimony included:

A denial of having executed any will after the first despite purported evidence such as a letter dated October 21, 1982 and an envelope marked with instructions “Buksan ito pagkalibing ko.”
A detailed account of the reconstitution process, including his confirmation of signatures and the content of the first will.

The record includes accounts of photographs, notarized testimonies of Atty. Mendoza, and declarations by witnesses (including Alfredo Barredo, Dr. Co, and Fernando Lim) concerning the execution of the alleged second will, all of which were marred by inconsistencies and credibility issues.

It was found that Heracio Revilla deliberately isolated Don Cayetano by transferring him from his residence on Claro M. Recto Avenue to Heracio’s house in Novaliches, Quezon City.
The environment in which the alleged second will was executed was marked by seclusion and secrecy, raising serious doubts about the absence of undue influence.
The differences in the dispositions of the first and second wills (such as the omission of the reservation for masses and the care of a family chapel in the second will) support the contention that the second will was designed to prejudice the rights of the other heirs.
Testimonies of the attesting witnesses and notary public were largely discredited due to internal inconsistencies and contradicting statements, further undermining the credibility of the alleged second will.

Whether the trial court and subsequently the Court of Appeals erred in disallowing the alleged second will purportedly executed by Don Cayetano Revilla on September 13, 1982.

Whether the testimonies and evidence regarding the execution of the second will, including inconsistencies in the witnesses’ accounts and the conditions under which it was allegedly executed, were sufficient to establish that the instrument did not reflect the true intention of Don Cayetano.
Whether the alleged undue influence and fraudulent actions by Heracio Revilla, such as isolating the testator and suppressing the existence of the alleged second will during critical proceedings, justify the court’s decision to disallow its probate.