Labrador v. Court of Appeals

Summary

This case involves the probate of Melecio Labrador's holographic will, which his heirs Sagrado, Enrica, and Cristobal sought to approve, while Jesus and Gaudencio opposed claiming it was invalid and superseded by a prior sale. The main issue was whether the will satisfied the dating requirement under Article 810 of the New Civil Code. The Court of Appeals denied probate finding the will undated, but the Supreme Court reversed, holding that the date 'March, 17th day, in the year 1968' appearing within the will's text was sufficient compliance with the law. The Court emphasized that the law does not specify where the date must appear, only that it be written by the testator's hand within the will itself. The decision approved the will's probate and ordered reimbursement of redemption costs, establishing that holographic wills need not follow conventional dating placement as long as the date is clearly indicated within the document by the testator.