G.R. No. 482 : March 21, 1902
FRUTO FELICIANO, ET AL., plaintiffs-appellants, vs. ESCOLASTICO FERNANDEZ, ET AL., defendants-appellees.

FACTS:
The plaintiffs-appellants sought the probate of the intestate estate of Doña Fernanda Trinidad. The defendant-appellee, Don Escolastico Fernandez, the surviving spouse, moved to dismiss the proceedings by presenting a certified copy of a will executed by the deceased on August 30, 1899, before Notary Public Don Matias Salamante y Villanueva of Pasig. The will instituted Don Escolastico Fernandez as the sole and universal heir. During the litigation, Don Escolastico Fernandez died, and the proceedings continued against his heirs. The Court of First Instance dismissed the plaintiffs’ complaint and quieted the claims against the defendants. The plaintiffs appealed, arguing for the annulment of the will on the primary ground that Notary Salamante’s authority was limited to the town of Pasig, and since the will was executed in the City of Manila, it was outside his jurisdiction and therefore null and void.

ISSUE:
Whether the will of Doña Fernanda Trinidad is null and void because it was executed before a notary public outside the territorial jurisdiction of his commission.

RULING:
The Supreme Court affirmed the judgment of the Court of First Instance, ruling that the will is valid. The Court held that under the Notarial Law of May 28, 1862, as extended to the Philippines by royal decree of February 15, 1889, a notary’s office encompasses the territorial limits of the judicial district where it is established. At the time, the town of Pasig and the district of Tondo (which included the City of Manila) were within the same judicial district. Consequently, Notary Salamante had the authority to authenticate the execution of the will in Manila. The Court further found the plaintiffs’ other allegations regarding formal defects in the execution of the will to be either inconsequential to its validity or not supported by the facts on record. Costs were taxed against the appellants.