Rivera v IAC, GR 75005-06, February 15, 1990

Facts:

The case of G.R. Nos. 75005-06, decided on February 15, 1990, revolves around a dispute over the
legitimacy of Jose Rivera's claim to be the sole heir of Venancio Rivera, a wealthy resident of Mabalacat,
Pampanga, who passed away on May 30, 1975. Jose Rivera filed a petition for the issuance of letters of
administration over Venancio's estate, asserting that he was Venancio's only legitimate son. Adelaido J.
Rivera opposed this petition, contending that Venancio had left two holographic wills instead of dying
intestate.

Adelaido initiated a separate petition for the probate of the holographic wills. The two cases were
consolidated, and Adelaido was appointed as the special administrator of the estate. After a joint trial,
the Regional Trial Court determined that Jose Rivera was not the son of the decedent Venancio Rivera.
The court also admitted the holographic wills to probate. The Intermediate Appellate Court
subsequently affirmed the trial court's decision.

Issue:

Whether Jose Rivera is the legitimate son of Venancio Rivera.

Whether the holographic wills left by Venancio Rivera are valid and should be probated.
Ruling:

The Supreme Court, in its ruling on G.R. Nos. 75005-06, upheld the decision in favor of Adelaido J.
Rivera:

On the issue of Jose Rivera's legitimacy, the Court found that he was not the legitimate son of the
deceased Venancio Rivera. Adelaido J. Rivera had argued that he and his siblings were the legitimate
children of Venancio and Maria Jocson, who lived together as husband and wife for many years, despite
not being able to present their parents' marriage certificate due to war-related record destruction. The
Court relied on the presumption of marriage, as codified in Article 220 of the Civil Code, which leans
towards the validity of marriage and legitimacy of children when in doubt. Jose's evidence did not
sufficiently challenge this presumption.

Regarding the validity of the holographic wills, the Court affirmed their authenticity and validity. The
holographic wills met the requirements of Article 810 of the Civil Code as they were written, dated, and
signed by Venancio Rivera himself. The Court determined that the provision of Article 811, which
mandates at least one witness who knows the testator's handwriting and signature, or three witnesses if
contested, did not apply because Jose Rivera lacked legal standing to contest the wills. Since he was not
the legitimate son of the deceased, his opposition did not trigger the requirement for additional
witnesses. The testimony of two witnesses who authenticated the wills was deemed sufficient.
In conclusion, the Supreme Court denied Jose Rivera's petition and upheld the decision of the
Intermediate Appellate Court. Adelaido J. Rivera was recognized as the legitimate heir, and the
holographic wills were declared valid and probated. The case serves as a reminder of the importance of
providing clear and convincing evidence in matters of inheritance and wills.