Title
Revilla vs. Court of Appeals
Case
G.R. No. 95329
Decision Date
Jan 27, 1993
Don Cayetano Revilla's second will, naming Heracio as sole heir, was disallowed due to doubts over authenticity, undue influence, and inconsistent witness testimonies. The first will remained valid.

Case Summary (G.R. No. 256285)

Relevant Facts

On January 28, 1978, Don Cayetano Revilla executed a last will and testament bequeathing all his properties to his nine nephews and nieces, including Heracio Revilla. The first will was admitted to probate on March 21, 1980. Following the probating of the first will, a significant event occurred on November 19, 1981, when the City Hall of Manila was destroyed by fire, resulting in the loss of many court documents. A petition for the reconstitution of records was filed, resulting in the revalidation of the first will.

Disputes Over the Second Will

Don Cayetano died on November 11, 1986. Shortly afterward, Heracio filed a petition to probate a second will that purportedly named him as the sole heir. This second will was dated September 13, 1982, and was met with resistance from his eight siblings who contested its validity, raising several objections regarding its execution and the mental state of the testator at the time.

Trial Court and Appellate Court Decisions

The trial court ultimately dismissed the claim to probate the second will, affirming that doubts existed regarding its authenticity and execution. The Court of Appeals mirrored these concerns, supporting the trial court’s findings regarding the inclusion of several key factors: the testator’s state of mind when the second will was allegedly executed, and the lack of credible evidence presented by the petitioner regarding the manner of execution.

Analysis of Testimony and Evidence

Significantly, during testimony, Don Cayetano, when reconstituting the first will, denied having executed any subsequent wills. Such a categorical denial weighed heavily in the court’s findings, bolstering the argument that the purported second will was executed under dubious circumstances. Examination of witnesses called by the petitioner was fraught with inconsistencies, leading to the conclusion that their testimonies lacked credibility.

Conclusion Regarding Undue Influence

The courts expressed concerns about the circumstances surrounding the execution of the second will, suggesting that undue influence may have been exercised by Heracio. This influence was thought to have potentially manipulated Don Cayetano into signing the document without full awareness of its implications. Additionally, the trial court highlighted that the omission of k

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