Kalaw v. Relova

Summary

This case involves a dispute over the probate of a holographic will executed by Natividad K. Kalaw. The will originally named Rosa K. Kalaw as sole heir but was later altered to name Gregorio K. Kalaw instead. When Gregorio petitioned for probate, Rosa opposed, arguing the alterations were not authenticated by the testatrix's full signature as required by Article 814 of the Civil Code. The trial court denied probate, and the Supreme Court affirmed, ruling that when the sole substantial provision of a holographic will is altered without proper authentication, the entire will becomes invalid. The Court distinguished cases where only specific altered words are invalidated, holding that here the testatrix's true intention cannot be determined with certainty, requiring invalidation of the entire testament.