Clemente Calde v. The Court of Appeals

Summary

This succession case involved the probate of Calibia Lingdan Bulanglang's will and codicil, opposed by relatives. The RTC initially allowed probate, but the Court of Appeals reversed, finding that witnesses' signatures appeared in different ink colors despite testimony that only one ballpen was used. This indicated the documents were not signed simultaneously as required by Article 805 of the Civil Code. The Supreme Court affirmed the disallowance, emphasizing that physical evidence (autoptic proference) showing different colored inks contradicted testimonial evidence. The case demonstrates the importance of strict compliance with formal requirements for will execution and the probative value of real evidence over contradictory testimony in probate proceedings.