### Facts:
The case revolves around the probate of the last will and testament of Torcuato J. Reyes, who died on May 12, 1992. On January 3, 1992, he executed his will, bequeathing assets to his wife, Asuncion “Oning” R. Reyes, and others. Julio A. Vivares was designated as the executor. Following Reyes’s death, Vivares filed a petition for the probate of the will in the Regional Trial Court of Mambajao, Camiguin, which was contested by Reyes’s recognized natural children and those from another relationship, alleging the will’s improper execution and undue influence.
The trial court, after extrapolating from witness testimonies, ruled that Asuncion Reyes was in an adulterous relationship with Torcuato, thus dismissing provisions of the will benefiting her. However, this decision, particularly regarding Paragraph II (a) and (b) of the will, was overturned by the Court of Appeals, which found no substantial evidence of the alleged marital infidelity or prior marriage of Asuncion Reyes, reinstating her as a beneficiary.
The petitioners contested the appellate court’s ruling in the Supreme Court, arguing the Court of Appeals erred in its findings and contradicted the law, public policy, and evidence on record.
### Issues:
1. Whether the court can inquire into the intrinsic validity of the will’s provisions during probate.
2. Whether the marriage between Torcuato Reyes and Asuncion Reyes was valid and, by extension, if Asuncion Reyes was lawfully a beneficiary under the will.
### Court’s Decision:
The Supreme Court affirmed the decision of the Court of Appeals and denied the petition for review. It highlighted that probate court jurisdiction typically does not extend to the intrinsic validity of the will, focusing instead on its due execution, formalities, and the testator’s capacity. The court underscored that the admissions within the will about the nature of the testator’s relationship with Asuncion did not, on the surface, invalidate the bequeathing provisions. Furthermore, the Court criticized the petitioners for their failure to substantiate claims about Asuncion’s previous marriage within the lower court proceedings, pointing out that new evidence could not be introduced at the review stage.
### Doctrine:
The case reiterates the doctrine that probate proceedings are primarily concerned with the extrinsic validity of the will – its formal execution and the testator’s capacity. Intrinsic validity, including questions about the legality of provisions within the will or the qualification of beneficiaries, typically falls outside the probate court’s purview, except under exceptional circumstances where practical considerations demand otherwise.
### Class Notes:
– **Jurisdiction of Probate Court**: Limited to examining the extrinsic validity of a will; intrinsic validity is generally not considered unless exceptional circumstances arise.
– **Intrinsic vs. Extrinsic Validity**: Intrinsic validity relates to the legality of the will’s contents, while extrinsic validity concerns the will’s external formalities and the testator’s capacity.
– **Evidence in Appeal**: Evidence not presented in lower court proceedings cannot be introduced for the first time in a petition for review in the Supreme Court.
– **Doctrine of Presumption of Marriage**: The declaration of the testator that a person is his wife carries weight and can establish a presumption of marriage, challenging the need for documentary evidence of the marriage’s legality.
### Historical Background:
This case illustrates the stringent approach of Philippine courts regarding the procedural aspects of will probate, emphasizing the distinction between the will’s extrinsic and intrinsic validity. It also highlights the evolving legal attitudes toward evidence and marital presumptions within the context of will contests, reflecting broader societal and legal shifts regarding family and inheritance law.
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