G.R. No. 204793 - Tanchanco vs. Santos

Consuelo Santiago Garcia (Decedent) died on April 4, 1997 at age 91. She was survived by her daughter Natividad Garcia Santos (Respondent) and predeceased daughter Remedios, whose children include Catalino and Ronaldo Tanchanco (Petitioners).
The Decedent left an estate of personal and real properties. On August 11, 1997, Catalino filed an intestate administration petition (Spec. Proc. No. 97-4244) before RTC Branch 113, Pasay City. On the same date, Natividad filed a petition to probate the Last Will and Testament of Consuelo (Spec. Proc. No. 97-4243) before RTC Branch 115.

The will, written in Tagalog on November 18, 1987 at Quasha Law Office in Makati City, was witnessed by Atty. Lallana, Atty. Tantuico, and Atty. Paras, and notarized by Atty. Marapao. All attesting witnesses testified to the Decedent’s sound mind, voluntary execution, and proper formalities.
The Tanchancos opposed probate, alleging defects in the attestation clause (omission of page count), unusual use of Tagalog, physical incapacity of the Decedent to travel, forgery of signature, undue favor to Natividad, and improper influence.

The two cases were consolidated before RTC Branch 115, Pasay City. Multiple witnesses—including the Quasha lawyers, security aide, and family members—testified regarding Decedent’s capacity, mobility, and circumstances of execution.
In a May 31, 2004 Decision, the RTC denied probate: it found the will “dubious,” noted the Decedent’s advanced age and inability to travel unaided to Makati, questioned the change of residence in the acknowledgment, and deemed the signature possibly forged and the document overly favorable to Natividad.

Natividad appealed. On June 25, 2012, the Court of Appeals reversed the RTC, holding that the will’s extrinsic validity was established: the witnesses were credible, the Decedent was of sound mind, mobility was not impossible, and formal defects (missing page count in the attestation clause) were cured by the acknowledgment. It found substantial compliance with Article 805 of the Civil Code.
The CA denied the Tanchancos’ motion for reconsideration on December 4, 2012.

The Tanchancos filed a Petition for Review on Certiorari under Rule 45, raising six main grounds (incapacity, forgery, non-compliance with Article 805, undue influence, disregard of RTC findings, and unfitness of Natividad as executrix).
The Supreme Court, in G.R. No. 204793, resolved these issues in its June 8, 2020 Decision.

Whether the will of Consuelo Santiago Garcia should be probated despite allegations that:

The Decedent was physically incapable of executing the will at Makati City in November 1987.
The will’s attestation clause omitted the number of pages required by Article 805 of the Civil Code.
The Decedent’s signature was forged and the will was executed under undue influence or improper pressure favoring Natividad.
The Court of Appeals erred in reversing the RTC and appointing Natividad as executrix, disregarding the trial court’s credibility findings.