G.R. No. 24566 - Sano vs. Quintana

The case involves the will of the deceased, Victoria Quintana, executed on March 22, 1924.
The probate of the will was initially allowed, indicating that prior proceedings accepted its validity.

The attestation clause of the will failed to state that the witnesses signed the will on the left margin of each page in the presence of the testatrix.
Section 618 of Act No. 190, as amended by Act No. 2645, requires that the attestation clause must clearly indicate that the testator signed the will and all its pages (or directed another to do so) in the presence of the three witnesses, and that these witnesses, in turn, signed the will and all its pages in the presence of the testator and of each other.

The case of Vy Coque vs. Navas L. Sioca (43 Phil. 405) was cited, wherein the court established that the attestation clause must contain a statement affirming that the witnesses signed in the presence of one another.
The absence of this crucial statement in the attestation clause of Victoria Quintana’s will was argued to undermine the authenticity and formal validity of the document.

The trial court initially allowed the probate of the will, indicating acceptance of its formalities despite the noted deficiency in the attestation clause.
On appeal, the judgment was reversed due to the failure to comply with the mandatory requirements of the attestation clause as prescribed by law.

Whether the attestation clause of the will complied with the statutory requirements set forth in Section 618 of Act No. 190, as amended by Act No. 2645.
Whether the omission of the statement “signed on the left margin of each page in the presence of the testator” in the attestation clause is sufficient to invalidate the will.
Whether the procedural irregularity in the attestation clause compromises the authenticity and reliability of the will, thereby warranting its nullification and denial of probate.