Case Summary (G.R. No. 120600)
Key Dates
• August 10, 1923: Testator appoints Vicente F. Lopez to administer his property.
• October 22, 1923: Guardianship petition filed by Margarita Lopez; court finds the testator mentally and physically incapacitated and names Vicente F. Lopez guardian.
• November 27, 1923–February 25, 1924: Testator confined in Philippine General Hospital.
• December 16 & 29, 1923: Attorney Mina interviews the testator and prepares a draft will.
• January 3, 1924: Will executed before witnesses and physicians at the hospital.
• February 25, 1924: Testator’s death.
• Trial court decision: Will denied probate on grounds of mental incapacity and fraud.
• Supreme Court decision: February 26, 1926.
Applicable Law
• Code of Civil Procedure (Jones Law period):
– Section 614: Testator must be of “sound mind.”
– Section 634(2): Disallow will if “insane or otherwise mentally incapable” at execution.
– Section 634(4): Disallow will if procured by “undue and improper pressure or influence.”
• Civil Code Article 666: Testamentary capacity judged at date of execution.
• Constitutional framework: Government under the Philippine Organic Acts and Jones Law; no native constitution until 1935.
Facts – Guardianship and Drafting of Will
- Prior to October 1923, Rodriguez suffered accidents, advancing age, and organic weakness.
- He voluntarily appointed Vicente F. Lopez as property administrator (Aug. 10, 1923).
- Margarita Lopez petitioned for guardianship on Oct. 22, 1923; testimony showed partial coherence and intelligence, but court nonetheless adjudged him incapacitated and named Vicente F. Lopez guardian.
- From Nov. 27, 1923, until death, Rodriguez was hospitalized under Dr. Elias Domingo; visitation restricted to select relatives (excluding Margarita Lopez).
- On Rodriguez’s suggestion, Vicente F. Lopez retained Attorney Maximino Mina, who interviewed the testator Dec. 16 and Dec. 29, obtained his testamentary instructions (all property to Vicente F. Lopez and Luz Lopez de Bueno), and prepared a rough draft.
Facts – Execution of the Will
• Jan. 3, 1924: At 3 p.m. in his hospital room, the testator and a small group of relatives, physicians, and attesting witnesses—including Drs. Calderon, Domingo, Herrera, De Asis, Elias Bonoan, and V. L. Legarda—assembled.
• Proponents’ account (Legarda, Drs. Calderon, Domingo, Herrera): The will was cleaned up, read aloud to the testator (who requested better light and read with eyeglasses), and signed by the testator and the three witnesses without hesitation or prompting. The testator expressed understanding of its contents.
• Opponent’s account (Dr. Bonoan): He alleged that Luz Lopez de Bueno told Rodriguez it was a complaint against one Castito, no one read the will to him, and it was signed through deceit.
• Additional evidence: A P1,000 “remuneratory donation” document by Luz Lopez de Bueno in favor of Dr. Bonoan dated Jan. 7, 1924 (disputed significance).
Facts – Medical and Behavioral Observations
• Calderon–Domingo–Herrera certificate (Jan. 3, 1924): Physical diagnoses of senility, hernia, decubitus; mental faculties “sound” except weak recent memory; testator understood and knew the contents of the will at signing.
• De los Angeles–Tietze–Burke certificate (March 15, 1924): Diagnosed senile dementia of a pathological degree; nearly total loss of recent memory; disorientation; impaired judgment and perception; inability to appreciate nature and consequences of dispositions; ongoing organic degeneration.
• Nursing records and testimony: Episodes of incoherent exclamations (“Maria,” “where is my key?”); complaints of generalized pain; childish emotional outbursts.
Issues
- Testamentary Capacity: Whether the testator on January 3, 1924, possessed the mental capacity to comprehend the nature, consequences, and objects of his bounty.
- Undue Influence: Whether relatives and beneficiaries exerted improper pressure to procure the testator’s signature against his free will.
Analysis – Testamentary Capacity
• Legal standard: Capacity to understand the business in which one is engaged, recollect one’s property and natural claimants, and comprehend dispositive effect.
• Presumption: Every adult is sane; burden on opponents to prove incapacity.
• Evidence conflict: Two physicians (Calderon committee) present at execution found sufficient capacity; thre
Case Syllabus (G.R. No. 120600)
Procedural History
- Original probate petition filed by Manuel Torres, executor named in the alleged will of Tomas Rodriguez y Lopez, seeking legalization of the will executed January 3, 1924.
- Opposition by first cousin Margarita Lopez on grounds of lack of testamentary capacity, undue influence, and fraud in obtaining the signature.
- Trial court denied probate after a prolonged hearing; findings included existing guardianship for senile dementia, evidence of fraud in inducement, and inability of testator to comprehend the transaction.
- Proponents appealed, specifying two errors: (1) finding lack of capacity at execution; (2) finding signatures obtained by fraud and deceit.
Factual Background
- Testator: Tomas Rodriguez y Lopez, died February 25, 1924 in Manila, age 76, left a considerable estate.
- Guardianship: On October 22, 1923, court adjudged Rodriguez incapacitated to manage himself or estate; Vicente F. Lopez appointed guardian.
- Hospitalization: Admitted to Philippine General Hospital November 27, 1923; diagnosis “Senility; Hernia inguinal; Decubitus”; strict visitor list excluding Margarita Lopez.
- Will preparation:
• December 16 and 29, 1923 – Attorney Maximino Mina interviewed Rodriguez in hospital, took instructions and prepared rough drafts.
• Intended execution December 31, 1923 postponed; drafts left with Santiago Lopez. - Execution January 3, 1924: Attesting witnesses Elias Bonoan, V. L. Legarda, A. de Asis; physicians Calderon, Domingo, Herrera observed.
Testamentary Capacity—Facts
- Guardianship judgment declared total physical and mental incapacity pre-dating will execution.
- Attesting witness Elias Bonoan testified:
• Rodriguez lying down, asked what to sign; told by Luz Lopez de Bueno it concerned a complaint against Castito.
• No one read the will to him; signature obtained through deceitful representations. - Counter-testimo