Short answer. A blind testator's notarial will must be read aloud twice before it is signed. Civil Code Article 808 requires the will to be read once by one of the subscribing witnesses, and again by the notary public before whom the will is acknowledged. Both readings are mandatory — skipping either one invalidates the will.
What the law says
If the testator is blind, the will shall be read to him twice; once, by one of the subscribing witnesses, and again, by the notary public before whom the will is acknowledged.
Civil Code, Article 808 — If the Testator Is Blind. Read the full provision →
Why the double-reading requirement exists
A person who cannot see cannot read the will to verify that what was drafted reflects what they intend to leave behind. The double-reading requirement substitutes for that visual check. Two independent readings — one from a witness who has no notarial authority, and one from the notary who does — give the blind testator two separate opportunities to hear the document and object if it does not match their wishes. Each reading is a separate safeguard: the witness reading is a first check, and the notary's reading is the second and more formal one at the moment of acknowledgment.
The two required readings in detail
Article 808 is specific about who reads and when. The first reading must be done by one of the subscribing witnesses — not all of them, not just anyone, but specifically one of the three witnesses required for a notarial will. The second reading must be done by the notary public at the acknowledgment stage, which comes after signing. Both readings must happen in the testator's presence so she can hear and follow along. A reading done outside her presence, or done by someone other than a subscribing witness or the notary, does not satisfy the requirement.
Other requirements that still apply
The double-reading rule adds to — not replaces — the general requirements for a valid notarial will. Your grandmother's will must still be in writing, signed at every page by the testator or her authorized representative, attested by three or more credible witnesses who also sign each page, and acknowledged before a notary public. The blind testator requirement in Article 808 is an additional layer on top of those baseline rules. If any of the general requirements are missing, the will is defective regardless of whether the two readings happened.
What to document at the will-signing
When a blind testator executes a will, the attestation clause — the portion signed by witnesses — should clearly state that the will was read twice as required: once by the named subscribing witness and again by the notary. The notarial acknowledgment should also reflect this. Good documentation inside the will itself reduces the chance that a relative will later challenge the will's validity on the grounds that the double-reading did not occur. If your grandmother is working with a lawyer to prepare the will, confirm that they are aware of Article 808 and will build the compliance record into the document.
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 petition for the probate of the last will, G.R. No. 246997, May 5, 2021 — read the decision on LawPhil →