Short answer. Only if you dated and signed each of them. Article 812 says that in a holographic (handwritten) will, dispositions written below the signature must be separately dated and signed by the testator to be valid. Additions you made below your signature without a fresh date and signature do not take effect.
What the law says
the dispositions of the testator written below his signature must be dated and signed by him in order to make them valid as testamentary dispositions
Civil Code, Article 812 — Dispositions Below the Signature. Read the full provision →
The extra date and signature are mandatory
A holographic will is one written entirely in the testator's own hand, and it must be dated and signed by him. Article 812 deals with what happens when the testator keeps writing after that signature. It says the dispositions of the testator written below his signature must be dated and signed by him in order to make them valid as testamentary dispositions. So an addition below the signature is not carried by the original date and signature at the top. It needs its own date and its own signature. Without both, that particular disposition is not a valid testamentary act, even though the rest of the will may be perfectly good.
Why the law demands it
The requirement guards against later tampering and against unfinished afterthoughts. Anything written under a signed will could, in principle, have been added by someone else, or jotted by the testator without the settled intention a will requires. Forcing a fresh date and a fresh signature for each below-signature disposition ties it firmly to the testator and fixes when he made it. The date also matters if the additions conflict with each other or with the body of the will, because the law can then tell which expression of his wishes came later. The formality is the proof of authenticity.
The rest of the will usually survives
Article 812 invalidates the defective additions, not necessarily the whole will. If the original holographic will above the signature is complete and properly dated and signed, it stands on its own; the un-signed matter written underneath simply drops out. The result is a valid will that does not include the extra dispositions the testator thought he had made. That is often the painful part: a testator who scribbles a further gift below his signature, meaning it to count, may leave a will that is valid but silent on exactly the thing he cared about most.
What to do instead
If you want to add to a holographic will, the safe course is to treat each addition as the law treats it — as its own testamentary disposition needing its own date and signature — or to rewrite the will in full so that everything sits above one date and one signature. Guesswork here is expensive, because the document is read after death, when the testator can no longer clarify what he meant. A will that has been added to over time, with some parts signed and dated and others not, is exactly the kind of document that invites a dispute among the heirs about what actually counts.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- In the Matter of the Allowance of the Will of Moises F. Banayad Apolonia Banayad Frianela vs. Servillano Banayad, Jr, G.R. No. 169700, July 30, 2009 — read the decision on LawPhil →