Case Digest (G.R. No. L-2538) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The special proceeding arose from the petition filed by Juana Juan Vda. de Molo, widow and universal heir of Mariano Molo y Legaspi, for the probate of his 1918 will in the Court of First Instance of Rizal. Mariano Molo died on January 24, 1941, in Pasay, Rizal, leaving no forced heirs in the ascending or descending line but survived by his wife and by his brother’s legitimate children, Luz, Gliceria, and Cornelio Molo, who opposed the petition. The decedent executed two testaments: the first on August 17, 1918 (Exhibit A), and the second on June 20, 1939 (Exhibit I), the latter expressly revoking the former. On February 7, 1941, petitioner sought probate of the 1939 will (SP No. 8022); it was admitted without opposition, later set aside on oppositors’ motion, and ultimately denied for lack of proof of due execution. On February 24, 1944, petitioner filed for probate of the 1918 will (SP No. 56), but wartime destruction of records made reconstitution impossible. Consequently, on Case Digest (G.R. No. L-2538) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Mariano Molo y Legaspi died on January 24, 1941, in Pasay, Rizal, leaving no compulsory heirs in the ascending or descending line.
- He was survived by his wife, Juana Juan Vda. de Molo (petitioner), and his nieces and nephew Luz, Gliceria, and Cornelio Molo (oppositors-appellants).
- Testaments and Proceedings
- Testator executed two wills:
- August 17, 1918 will (Exhibit A).
- June 20, 1939 will (Exhibit I), containing a clause revoking the 1918 will.
- Probate history:
- February 7, 1941 petition to probate the 1939 will—initially admitted unopposed, then set aside and disallowed for lack of proper execution.
- February 24, 1944 and September 14, 1946 petitions to probate the 1918 will—oppositions filed on grounds of estoppel, improper execution, and revocation; original records lost in the war; re-filed proceedings; May 28, 1948 order admitting the 1918 will to probate.
Issues:
- Did petitioner deliberately frustrate probate of the 1939 will to secure the 1918 will?
- Is petitioner estopped from litigating probate of the 1918 will?
- Does petitioner come with “unclean hands,” barring relief?
- Was the 1918 will validly executed according to legal formalities?
- Was the 1918 will revoked by Mariano Molo’s own act (destruction)?
- Does the disallowed 1939 will nonetheless revoke the 1918 will?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)