Samaniego-Celada vs. Abena

A petition for review under Rule 45 is limited to questions of law; findings of fact by the CA are conclusive and binding on the SC. Furthermore, errors in the attestation clause regarding the number of pages do not invalidate a will if the pages are consecutively lettered and the will substantially complies with Article 805 of the Civil Code.

Margarita S. Mayores died single and without ascending or descending heirs, survived only by collateral relatives (first cousins). She executed a notarial will bequeathing properties to her lifelong companion (respondent) and the companion's nephews, leaving nothing to her surviving first cousins.

• Original Filing: Petitioner filed a petition for letters of administration (SP Proc. No. M-1531, RTC Makati)
• Original Filing 2: Respondent filed a petition for probate of will (SP Proc. No. M-1607, RTC Makati); consolidated with SP Proc. No. M-1531
• Lower Court Decision: March 2, 1993 — RTC declared the will probated and designated respondent as executor
• Appeal: Petitioner appealed to the CA (CA-G.R. CV No. 41756)
• CA Decision: October 13, 2000 — CA affirmed the RTC decision in toto
• SC Action: Petitioner filed a Petition for Review on Certiorari under Rule 45

• The Parties: Petitioner Paz Samaniego-Celada was the first cousin of decedent Margarita S. Mayores. Respondent Lucia D. Abena was Margarita's lifelong companion since 1929.
• Death of Decedent: Margarita died on April 27, 1987, single, with no ascendants or descendants. Her parents, grandparents, and siblings had predeceased her.
• The Last Will: On February 2, 1987, Margarita executed a Last Will and Testament bequeathing one-half of her undivided share in a Singalong property and a Makati property to respondent and respondent's nephews in equal shares. She left all personal properties to respondent and designated her as sole executor.
• The Probate Battle: Petitioner sought letters of administration, while respondent sought probate of the will. The cases were consolidated.
• RTC Findings on Validity: The RTC found the will valid. It held that Margarita was of sound mind (presumed under Art. 800, and oppositors' own doctor witness testified she could converse normally). It found no undue influence (a photo showed Margarita smiling while signing). It held that the error in the attestation clause stating the will had three pages instead of two was not fatal because the pages were consecutively lettered (A, B, C), safeguarding against omission.
• CA Affirmation: The CA affirmed the RTC's findings on the validity of the will and the testator's sound mind.

• The will failed to comply with the formalities of Article 805 of the Civil Code because it was not signed by the testator in the presence of the instrumental witnesses and the witnesses in the presence of one another.
• The signatures of the testator on pages A, B, and C appear different, indicating they were not signed on the same day.
• The will was procured through undue influence and pressure because Margarita was weak, sickly, jobless, and entirely dependent on respondent and her nephews, compelling her to sign.
• Petitioner and her siblings should be declared legal heirs under Articles 1009 and 1010 of the Civil Code as the only living collateral relatives.

• The petition raises questions of fact, not law, and CA findings of fact are final, conclusive, and not reviewable by the SC.
• The CA already ruled on the assigned errors, sustaining the RTC's findings that the will was validly executed, formalities were complied with, and the testator was of sound mind.

• Procedural Issues: Whether the petition for review raises pure questions of fact barred under Rule 45 of the 1997 Rules of Civil Procedure.
• Substantive Issues:
  • Whether the will is invalid for failure to comply with the formalities required by Article 805 of the Civil Code.
  • Whether the will is invalid because it was procured through undue influence and pressure.
  • Whether petitioner and her siblings are the legal heirs of Margarita entitled to the estate.

• Procedural: The SC ruled that the issues raised are pure questions of fact, which may not be subject of a petition for review on certiorari under Rule 45. Section 1 of Rule 45 limits the SC's review to questions of law only. The SC is not a trier of facts. The findings of fact of the CA are conclusive and binding when supported by substantial evidence, and none of the recognized exceptions apply.
• Substantive: Even on the merits, the SC found no reason to disturb the RTC and CA findings.
• On formalities: The error in the number of pages in the attestation clause was not material to invalidate the will. The pages were consecutively lettered (A, B, C), providing a sufficient safeguard against page omission. This falls under the doctrine of liberal interpretation under Article 809 of the Civil Code.
• On sound mind and undue influence: The testator is presumed of sound mind under Article 800. Oppositors failed to prove mental incapacity; their own witness testified she could engage in normal conversation. A photo showed the testator smiling and in a good mood while signing, negating undue influence.
• On heirship: Petitioner and her siblings are not compulsory heirs under Article 887 of the Civil Code. Since the decedent validly disposed of her properties in a duly probated will, petitioner has no legal right to claim any part of the estate.

• Doctrine of Liberal Interpretation (Art. 809, Civil Code) — Defects and imperfections in the form of attestation or in the language used therein shall not render the will invalid if it is proved that the will was in fact executed and attested in substantial compliance with all the requirements of Article 805, provided there is no bad faith, forgery, fraud, or undue/improper pressure and influence. Applied: An error in the attestation clause regarding the number of pages did not invalidate the will because the pages were consecutively lettered, safeguarding against omission, and there was substantial compliance with Art. 805.
• Presumption of Sound Mind (Art. 800, Civil Code) — The testator is presumed to be of sound mind unless the contrary is proved. Applied: Oppositors failed to overcome the presumption; evidence showed the decedent could engage in normal conversation and physical weakness does not equate to mental incapacity.
• Conclusiveness of CA Findings of Fact — Findings of fact of the CA are final, conclusive, and binding on the SC and not reviewable, unless the case falls under recognized exceptions: (1) conclusion grounded on speculation; (2) inference manifestly mistaken; (3) grave abuse of discretion; (4) judgment based on misapprehension of facts; (5) conflicting findings of fact; (6) CA went beyond issues contrary to admissions; (7) findings contrary to trial court; (8) findings without citation of specific evidence; (9) facts set forth undisputed by respondent; (10) findings premised on absence of evidence but contradicted by record. Applied: None of the exceptions were present; petitioner's issues were purely factual.

• Rule 45, 1997 Rules of Civil Procedure — Limits the SC's review to questions of law only. Applied to dismiss the petitioner's factual challenges.
• Article 805, Civil Code — Prescribes the formalities for executing a notarial will (subscription by testator, attestation by 3 credible witnesses, signing on left margin, numbering of pages). Applied: The SC found substantial compliance with this article.
• Article 809, Civil Code — Codifies the doctrine of liberal interpretation in the probate of wills. Applied to uphold the will despite the error in the attestation clause.
• Article 800, Civil Code — Establishes the presumption that the testator was of sound mind. Applied to defeat petitioner's claim of mental incapacity.
• Article 887, Civil Code — Enumerates the compulsory heirs. Applied to establish that first cousins are not compulsory heirs and have no legal right to the estate when there is a valid will.
• Articles 1009 & 1010, Civil Code — Govern intestate succession by collateral relatives. Invoked by petitioner, but rendered inapplicable because the decedent left a valid will.