### Facts:
The case involves the holographic will of Annie Sand who passed away on November 25, 1982. The will named various individuals, including the Spouses Roberto and Thelma Ajero (petitioners) and Clemente Sand among others, as devisees. The petitioners filed for the allowance of the will on January 20, 1983. Private respondent Clemente Sand and Dr. Jose Ajero opposed the petition on various grounds such as the authenticity of the handwriting in the will, unauthenticated alterations and corrections, and the undue influence exerted on the testatrix. Despite oppositions, the RTC admitted the will to probate. The decision was based on the testament’s identity, due execution, and the testatrix’s testamentary capacity, dismissing claims of undue pressure or influence.
Upon appeal, the Court of Appeals reversed the RTC’s decision, ruling the will non-compliant with Articles 813 and 814 of the New Civil Code regarding unsigned and undated dispositions and unauthenticated alterations. The Spouses Ajero then filed this appeal to the Supreme Court.
### Issues:
1. Whether the holographic will was executed in accordance with the formalities prescribed by law.
2. The effect of unauthenticated alterations, cancellations, or insertions on the validity of the will.
3. The validity of the disposition regarding the property in Cabadbaran, Agusan del Norte.
### Court’s Decision:
The Supreme Court granted the petition, reversing the Court of Appeals’ decision and reinstating the RTC’s ruling, with the exception of the disposition of the entire Cabadbaran property. The Court clarified that Articles 813 and 814 of the New Civil Code affected the validity of the dispositions in the holographic will but did not affect its probate. Thus, non-compliance with these provisions would not invalidate the holographic will but only the specific unauthenticated alterations, cancellations, or insertions. However, Annie Sand could not validly dispose of the entire Cabadbaran property, as she shared ownership with her father’s other heirs.
### Doctrine:
The Court reiterated the principle that the law on succession favors testate over intestate succession and that the formalities required by law aim to prevent fraud and assure the will’s authenticity. The requirements specific to holographic wills, particularly under Article 810 of the New Civil Code, are essential to its probate, while non-compliance with Articles 813 and 814 affects only the validity of the specific dispositions but not the entirety of the will.
### Class Notes:
– **Holographic Will Requirements**: Must be entirely written, dated, and signed by the testator’s hand (Article 810, NCC).
– **Authentication of Changes**: Lack of authentication of alterations, cancellations, or insertions in a holographic will affects the specific dispositions but not the will’s overall validity (Articles 813 and 814, NCC).
– **Probate of Holographic Will**: The issues to be resolved are the will’s identity, compliance with prescribed formalities, testamentary capacity of the testator, and the voluntary execution of the will.
### Historical Background:
This case illustrates the judicial balancing act between strict adherence to procedural requirements for holographic wills and the overarching principle to honor the testator’s intentions as much as possible within the bounds of law. It underscores the autonomy and flexibility granted to testators in expressing their last wishes through holographic wills, contrasting them with the more rigidly structured formal wills.
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