G.R. No. 145545 ; June 30, 2008
PAZ SAMANIEGO-CELADA, petitioner, vs. LUCIA D. ABENA, respondent.

FACTS

Margarita S. Mayores died single and without direct heirs. She was survived by collateral relatives, including her first cousin, petitioner Paz Samaniego-Celada. Before her death, Margarita executed a notarial will bequeathing her real and personal properties to her lifelong companion, respondent Lucia D. Abena, and several other named beneficiaries. Respondent was also designated as the sole executor. Petitioner filed a petition for letters of administration over Margarita’s estate. Subsequently, respondent filed a petition for the probate of the will. The cases were consolidated.
The Regional Trial Court admitted the will to probate, declared it validly executed, and ordered the issuance of letters testamentary to respondent as executor. The Court of Appeals affirmed this decision in toto. Petitioner now seeks a review, arguing the will is invalid for non-compliance with legal formalities and due to undue influence, and that she and her siblings should be declared the legal heirs.

ISSUE

The primary issue is whether the Supreme Court can review the factual findings of the lower courts regarding the validity of the will’s execution and the alleged undue influence.

RULING

The petition is denied. The Supreme Court ruled that the issues raised by petitioner are questions of fact inappropriate for a petition for review under Rule 45, which is limited to questions of law. Petitioner’s specific challenges—whether the testator signed in the presence of the witnesses, whether all signatures were affixed on the same day, and whether undue influence was exerted—require a re-evaluation of the evidence, including witness testimonies and the physical will itself. Both the trial court and the Court of Appeals made concurrent factual findings that the will complied with all formalities under Article 805 of the Civil Code and was executed without undue influence while the testator was of sound mind.
The Court emphasized that in probate proceedings, the court’s duty is limited to examining the will’s extrinsic validity—its due execution, the testator’s testamentary capacity, and the absence of coercion or undue influence. The trial court faithfully performed this duty. The alleged inconsistencies in signatures and the claim of influence based on the testator’s dependent state were factual matters already resolved by the lower courts. Their factual findings are final and conclusive. Since no compelling reason exists to deviate from this rule, the Supreme Court upheld the probate of the will and the appointment of respondent as executor.