Short answer. Only if you dated and signed them. Article 812 says that in a holographic will, any dispositions written below your signature must themselves be dated and signed to take effect. Additions sitting under the signature without their own date and signature are not valid testamentary dispositions.
What the law says
In holographic wills, 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 →
What Article 812 requires
Article 812 provides that in holographic wills, 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. A holographic will is one written entirely in the testator's own hand, dated and signed by him. The signature normally marks the end of it. Anything you add afterwards, in the space below that signature, is treated as a fresh disposition — and the law asks it to carry its own date and signature, just as the original body did, before it will count for anything.
Why the extra date and signature matter
The purpose is to be sure the later lines are genuinely yours and genuinely meant as part of the will. Text below a signature could be added by anyone, at any time, including after death; requiring your date and signature on it ties the addition to you and to a moment. It also shows deliberateness — that you meant these words to dispose of property, not merely a note or an afterthought. So the two small formalities do real work: they authenticate the addition and confirm you intended it to operate as a testamentary disposition rather than a scribble.
What happens to additions that lack them
If the lines below your signature are neither dated nor signed, they fail as testamentary dispositions — they simply do not take effect, and the estate is distributed as though they were not written. Importantly, that does not invalidate the will above your signature; the properly executed body stands, and only the defective addition drops out. So the practical risk is not that you destroy your will by adding to it, but that the very gift you thought you had made below the line never happens. If those later words matter to you, they have to meet the article's requirement.
The safe way to add to a holographic will
If you want to add a disposition, treat the addition with the same care as the original: write it in your own hand, then date and sign it immediately beneath. Better still, where the changes are substantial, write a fresh holographic will that restates everything you intend and revokes the earlier one, so a probate court is not left reconciling a signed body with an unsigned tail. Keep the will somewhere its integrity is clear. The cheapest way to lose a gift is to jot it under a signature and never date and sign it, and that mistake is easy to avoid.
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 →