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ANTONIO B. BALTAZAR v. LORENZO LAXA

FACTS:

Paciencia Regala executed a notarial will on September 13, 1981, bequeathing all her properties to respondent Lorenzo R. Laxa and his family. Lorenzo filed a petition for the probate of Paciencia's will after her death, while petitioner Antonio Baltazar opposed it, claiming that the properties in question belong to Nicomeda Regala Mangalindan and not Paciencia. Several other petitioners later joined Antonio and opposed the probate of the will, arguing that the properties were conjugal properties acquired during Antonio's marriage to Paciencia. They also opposed the appointment of Lorenzo as the administrator of the properties. The RTC denied the requests of both Lorenzo and Antonio to be appointed as administrators. Testimonies were heard from witnesses, including Dra. Limpin, Lorenzo, Monico Mercado, and the petitioners. Dra. Limpin testified about the age of her father when he notarized the will and the living arrangements of Paciencia at the time of the execution. Lorenzo testified about his relationship with Paciencia, denying the use of force or trickery to make her execute the will. Monico Mercado testified about his father's condition, stating that he can no longer talk or express himself due to brain damage. The petitioners also presented testimonies and identified the will. The main issue is whether the will was sufficiently established to warrant its allowance for probate.

The case involves the probate of Paciencia Mañalang's last will and testament. Antonio Mendoza opposed the probate, claiming that the properties in question were conjugal properties acquired during his marriage to Paciencia. Other petitioners also opposed the probate, arguing that the will was null and void because the properties had not been transferred or titled to Paciencia before her death. They also opposed the appointment of Lorenzo as the administrator of the properties. The RTC denied the requests of both Lorenzo and Antonio to be appointed as administrators. Testimonies were heard from Dra. Limpin, Lorenzo, Monico Mercado, and the petitioners. Dra. Limpin testified about the age of her father when he notarized the will and the living arrangements of Paciencia at the time of the execution. Lorenzo testified about his relationship with Paciencia, denying the use of force or trickery. Monico Mercado testified about his father's condition. The petitioners also presented testimonies and identified the will. The main issue is whether the will was sufficiently established to warrant its allowance for probate.

Paciencia Regala executed a notarized will on September 13, 1981, bequeathing her properties to her son, Lorenzo, and his family. However, the will was not signed by Paciencia when shown to her son, Antonio, along with another document. Antonio kept the unsigned documents and later turned them over to another person. The RTC denied the probate of the will, finding that Paciencia lacked testamentary capacity. The CA reversed the RTC's decision, ruling that Paciencia was of sound mind when she executed the will, and there was no evidence of coercion or trickery. Petitioners sought review of the CA's decision, alleging errors in the probate proceedings. The main issue is whether the will was sufficiently established to warrant its allowance for probate.

ISSUES:

  1. Whether there was faithful compliance with the formalities laid down by law in the execution of the will.

  2. Whether the testator was of unsound mind at the time of the execution of the will.

  3. Whether or not Paciencia was aware of the nature of the will she executed and the objects of her bounty.

  4. Whether or not the allegations of duress, influence of fear or threats, undue and improper influence, pressure, fraud, and trickery in the execution of the will have been proven.

  5. Whether or not the authenticity of Paciencia's will has been established despite the non-appearance of all subscribing witnesses and the notary public.

  6. Whether the probate of Paciencia's Will may be allowed despite the incapacity and failure of the subscribing witness and the notary public to testify in court.

RULING:

  1. The court held that there was faithful compliance with the formalities laid down by law in the execution of the will. The signatures of the testator, instrumental witnesses, and notary public were all present and evident on the will. The attestation clause also explicitly stated that the testator and instrumental witnesses signed the will in the presence of each other, and the witnesses attested and subscribed to the will in the presence of the testator and each other. Compliance with the formalities prescribed by law was apparent from the face of the will.

  2. The court held that the burden to prove that the testator was of unsound mind at the time of the execution of the will lies on the shoulders of the petitioners. The court found no substantial evidence, medical or otherwise, that would show that the testator was of unsound mind at the time of the execution of the will. The court also considered the presumption that every person is of sound mind, and there was no showing that the testator was publicly known to be insane one month or less before making the will. Therefore, the petitioners failed to discharge their burden of proving that the testator was of unsound mind.

  3. The Court is convinced that Paciencia was aware of the nature of the will she executed and the objects of her bounty. The Court takes into consideration the special bond between Paciencia and the devisees, particularly Lorenzo and his family, which supports the authenticity of the will.

  4. The allegations of duress, influence of fear or threats, undue and improper influence, pressure, fraud, and trickery have not been proven. The Court considers these allegations as bare arguments unsupported by concrete, substantial, and credible evidence on record. Consequently, the Court cannot be compelled to uphold said allegations.

  5. The authenticity of Paciencia's will has been established despite the non-appearance of all subscribing witnesses and the notary public. The Court notes that the inability of these witnesses to appear and testify in court was satisfactorily explained during the probate proceedings.

  6. The probate of Paciencia's Will may be allowed despite the incapacity and failure of the subscribing witness and the notary public to testify in court. The court held that Lorenzo, the proponent of the Will, was able to satisfactorily account for the incapacity and failure of the witnesses to testify. The court emphasized that a testament may not be disallowed just because the attesting witnesses declare against its due execution and that what is decisive is that the court is convinced by the evidence before it that the Will was duly executed. The court also ruled that the very existence of the Will is prima facie proof that the testatrix desired her estate to be distributed accordingly, and it is incumbent upon the state to give effect to such desire independently of the attitude of the parties involved.

PRINCIPLES:

  • Courts in probate proceedings are tasked to determine the extrinsic validity of a will, specifically its due execution, based on the formalities laid down by law.

  • The formalities for the execution of a will include the testator's subscription at the end of the will, attestation and subscription by three or more credible witnesses, numbering and signing of each page of the will, and acknowledgment before a notary public.

  • Forgetfulness alone does not render a person mentally unsound and unfit to execute a will. To be of sound mind, it is sufficient that the testator at the time of making the will knew the nature of the estate to be disposed of, the proper objects of his bounty, and the character of the testamentary act.

  • The law presumes that every person is of sound mind, and the burden of proving otherwise lies on the person who opposes the probate of the will. However, if the testator was publicly known to be insane one month or less before making the will, the proponent of the will must prove that it was made during a lucid interval.

  • Testamentary disposition should be respected unless there is concrete and substantial evidence to prove otherwise.

  • Bare allegations of duress or influence of fear or threats, undue and improper influence and pressure, fraud and trickery cannot be used as a basis to deny the probate of a will.

  • The court should be convinced by the evidence presented before it that the will was duly executed.

  • Compliance with procedural requirements in the probate of wills, such as the appearance of subscribing witnesses, may be excused if their inability to appear and testify in court is satisfactorily explained.

  • A testament may not be disallowed just because the attesting witnesses declare against its due execution; what is decisive is that the court is convinced by the evidence before it that the Will was duly executed in the manner required by law.

  • The very existence of a Will is prima facie proof that the testatrix desired her estate to be distributed in the manner stated therein, and it is incumbent upon the state to give effect to such desire independently of the attitude of the parties involved.