Sixto Timbol y Manalo v. Januaria Manalo

Summary

This case involved the probate of Cesarea Manalo y Manalo's will executed in 1898 during the Spanish regime. Sixto Timbol, named as heir and executor, sought probate using a certified copy since the original was lost. Several family members contested, challenging the will's validity and execution. The Supreme Court affirmed the trial court's admission of the will to probate, finding it was properly executed under the Civil Code as a nuncupative will before a notary and three witnesses. The Court established that certified copies can serve as evidence when originals are lost and that wills executed before the Code of Civil Procedure took effect remain valid if they complied with prior law. The decision clarified important principles regarding will probate, evidence of lost documents, and the retroactive application of procedural laws in succession matters.