- Petitioner
- Spouses Roberto
- Respondent
- The Court of Appeals
- Citation
- G.R. No. 106720
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Puno, J.
- Decided
- September 15, 1994
Summary
This case involves the probate of Annie Sand's holographic will, contested by heir Clemente Sand and Dr. Jose Ajero. The RTC admitted the will to probate, finding it authentic and properly executed. The Court of Appeals reversed, holding the will invalid due to non-compliance with Articles 813 and 814 regarding unsigned dispositions and unauthenticated alterations. The Supreme Court reinstated the RTC decision, clarifying that only Article 810's requirements (handwritten, dated, signed by testator) are essential for probate of holographic wills. Articles 813 and 814 affect specific dispositions' validity, not the will's overall probate. However, the Court affirmed that decedent cannot dispose of the entire Cabadbaran property as she was not its sole owner. The decision establishes important precedent distinguishing between requirements for probate versus validity of specific testamentary dispositions in holographic wills.