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heir with another, and the same did not carry the requisite full
signature of the testator, or simply put, where the change affects
the essence of the will of the testator, the entirety of the will is
voided or revoked. To rule that the first will should be given effect is
to disregard the testatrix' change of mind. However, this change of
mind cannot be given effect either as she failed to authenticate it in
accordance with Art. 814, or by affixing her full signature.
Dispositive: Petition failed
Additional Important Note:
General Rules:
When a number of erasures, corrections, cancellation, or insertions
are made by the testator in the will but the same have not been
noted or authenticated with his full signature, only the particular
words erased, corrected, altered will be invalidated, not the entirety
of the will.
Exception:
1. Where the change affects the essence of the will of the testator;
Note: When the holographic will had only one substantial provision,
which was altered by substituting the original heir with another, and
the same did not carry the requisite full signature of the testator,
the entirety of the will is voided or revoked.
Reason: What was cancelled here was the very essence of the will;
it amounted to the revocation of the will. Therefore, neither the
altered text nor the original unaltered text can be given effect.
(Kalaw v. Relova, G.R. No. L-40207, Sept. 28, 1984)
2. Where the alteration affects the date of the will or the signature
of the testator.
3. If the words written by a 3rd person were contemporaneous with
the execution of the will, even though authenticated by the testator,
the entire will is void for violation of the requisite that the
holographic will must be entirely in the testators handwriting.