SPS. ROBERTO v. CA

FACTS:

The case involves the appeal of a decision from the Court of Appeals reversing the trial court's admission of a holographic will to probate. The holographic will was submitted for probate by the petitioners, who claimed that the decedent, Annie Sand, was of sound mind and capacity when she executed the will. Private respondent, Clemente Sand, opposed the probate, arguing that the will did not comply with the formalities required by law and was procured through undue influence. Dr. Jose Ajero also opposed the disposition of a house and lot mentioned in the will, claiming that the decedent did not have sole ownership over it. Despite the oppositions, the trial court admitted the will to probate, finding that it was identical to the one executed by the testatrix and that the formalities required by law were complied with. However, the Court of Appeals reversed the decision, stating that the holographic will failed to meet the requirements for its validity, specifically the requirement of dating the dispositions in the will.

ISSUES:

  1. Whether the holographic will complies with the requirements for its validity.

  2. Whether the holographic will was executed under undue influence or improper pressure.

RULING:

  1. The Court of Appeals held that the holographic will failed to meet the requirements for its validity because it did not comply with Articles 813 and 814 of the New Civil Code.

  2. The Court of Appeals did not find convincing evidence that the holographic will was procured by undue influence or improper pressure.

PRINCIPLES:

  • The holographic will must comply with the requirements under the law to be considered valid.

  • In case of doubt, testate succession should be preferred over intestate succession.