Case Summary (G.R. No. 174489)
Procedural History
After Paciencia’s death, Lorenzo filed for probate. No initial opposition emerged. At trial, Petitioners—claiming interest as successors of another heir—opposed on grounds of improper transfer of title, Lorenzo’s disqualification as a U.S. resident, lack of testamentary capacity, undue influence, and noncompliance with formalities. The RTC denied probate, crediting testimony that Paciencia was forgetful (“magulyan”) and mentally unsound. On appeal, the CA reversed, found formalities and capacity proven, and allowed probate. Petitioners sought review before the Supreme Court.
Issues
- Whether the Court of Appeals erred in admitting the will despite alleged non-compliance with Rule 76 Sec. 11 (production of subscribing witnesses and notary).
- Whether the CA’s factual findings on the testatrix’s mental capacity, voluntariness, and due execution are contrary to evidence.
- Whether petitioners met their burden to prove the testatrix was not of sound mind at execution.
Extrinsic Validity and Formalities
Under Rule 75 Sec. 1 of the Rules of Court, allowance of a will is conclusive as to due execution. Articles 805-806 of the Civil Code require (i) testator’s signature or at express direction, (ii) attestation by at least three credible witnesses in each other’s and the testator’s presence, (iii) subscription on every page, and (iv) acknowledgment before a notary. The will’s face shows compliance: numbering, marginal signatures, attestation clause, signatures of testatrix, witnesses, and notary. Petitioners conceded the genuineness of the signature but questioned mental capacity and voluntariness.
Testamentary Capacity and Burden of Proof
Articles 799-800 establish a presumption of sound mind; capacity requires knowing the nature of one’s estate, proper beneficiaries, and the testamentary character of the act. Petitioners presented Rosie Mateo’s testimony that Paciencia was “forgetful,” but no medical or expert proof of insanity or paranoia. Oppositors failed to show Paciencia was publicly known insane within one month of execution, thereby failing to overcome the presumption. Dra. Limpin’s credible firsthand testimony of Paciencia’s lucidity when signing carries greater weight.
Duress, Undue Influence, and Fraud Allegations
Petitioners alleged that Lorenzo or others unduly influenced, threatened, or tricked Paciencia into executing the will, basing claims on purported conversations between Paciencia and Antonio Baltazar. The record shows no concrete evidence of coercion or fraud. The long-standing close relationship between Paciencia and Lorenzo, and her voluntary presence at the notarial act, support voluntariness. Bare allegations without proof cannot defeat a duly executed will.
Compliance with Rule 76 Sec. 11
Rule 76 Sec. 11 requires production or satisfactory accounting for subscribing witnesses and notary. Petitioners faulted the absence of two instrumental witnesses
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Facts
- Testatrix Paciencia Regala, a 78-year-old spinster without descendants or siblings, executed a notarial will in Pampango on September 13, 1981, at Judge Ernestino G. Limpin’s home office.
- The will entitled “Tauli Nang Bilin o Testamento ni Miss Paciencia Regala” was read twice to her; she declared it her last testament, signed page 3 at the end and the left margins of pages 1, 2, and 4.
- Instrumental witnesses Dra. Maria Lioba A. Limpin, Francisco Garcia, and Faustino R. Mercado attested and subscribed on the attestation clause and left margins, in the presence of Paciencia and one another, while Judge Limpin notarized and signed.
- Paciencia bequeathed all enumerated properties to her nephew Lorenzo R. Laxa, his wife Corazon F. Laxa, and their children Luna Lorella and Katherine Ross Laxa, and commanded masses and the fulfillment of prior testamentary wishes of her predecessor.
- Six days later, Paciencia departed for the United States and resided with Lorenzo’s family until she died on January 4, 1996; the original will remained with Judge Limpin.
Procedural History
- April 27, 2000: Lorenzo filed with the RTC of Guagua, Pampanga (SP. Proc. No. G-1186) a petition for probate of the will and for letters of administration in his favor; no opposition appeared after publication.
- June 13, 2000: RTC set June 22, 2000 for presentation of evidence; Lorenzo offered Dra. Limpin’s testimony identifying the will and notarization signatures but Judge Limpin was unable to testify due to stroke and brain surgery.
- June 23, 2000: Petitioner Antonio Baltazar filed opposition claiming property interests of Nicomeda Regala Mangalindan; July 20, 2000: Supplemental opposition argued Paciencia had no title over properties and that Lorenzo was disqualified as administrator for being a U.S. resident.
- September 26, 2000: Amended opposition alleged formal defects in execution, lack of testamentary capacity, duress, undue influence, fraud, and forgery of signature; petitioners sought denial of probate and appointment of Antonio as administrator.
- January 29, 2001: RTC denied both Lorenzo’s and Antonio’s requests for letters of administration; probate procee