Short answer. Yes. Every page of a notarial will must be numbered, and the Civil Code is specific about how: the pages are numbered correlatively, in letters, placed on the upper part of each page. That requirement is separate from the marginal signatures on every page.
What the law says
all the pages shall be numbered correlatively in letters placed on the upper part of each page
Civil Code, Article 805 — Formalities of a Notarial Will. Read the full provision →
Three things the wording actually specifies
The clause is unusually precise for a code provision, and each element does work. Correlatively means the numbers run in an unbroken sequence, so a gap is detectable. In letters means written out as words rather than figures, because a figure can be altered with a stroke of a pen and a written word cannot be so easily. And the number goes on the upper part of each page, a fixed and conspicuous location rather than wherever there happens to be space.
Numbering and marginal signatures are separate requirements
The same sentence of the article requires that the testator, or the person who wrote his name at his direction, and the instrumental witnesses shall also sign each and every page thereof, except the last, on the left margin. That is a different safeguard, done by different marks, in a different place on the page. A will that carries proper marginal signatures but no numbering has satisfied one requirement and not the other; they do not substitute for each other.
What the numbering is protecting against
Both devices exist because a multi-page will is physically vulnerable. Pages can be removed, replaced, or inserted after execution. Sequential numbering in written words, in a fixed position, makes an interpolation visible; marginal signatures make a substituted page identifiable; and the attestation's statement of the total page count fixes the document's size at the moment of execution. Read together, the three are a layered defence rather than three versions of the same rule.
Holographic wills are outside this article
The article opens by addressing every will, other than a holographic will, so none of these formalities — the witnesses, the marginal signatures, the numbering in letters — is being imposed on a will written entirely in the testator's own hand. A holographic will is governed by its own provisions elsewhere in the Code. If you are checking a document against this article, the first question is which kind of will you are actually holding.
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 will of Consuelo, G.R. No. 204793, June 8, 2020 — read the decision on LawPhil →
- Margie Santos Mitra vs. Perpetua L. Sablan-Guevarra, et al, G.R. No. 213994, April 18, 2018 — read the decision on LawPhil →
- Felix Azuela vs. Court of Appeals, et al, G.R. No. 122880, April 12, 2006 — read the decision on LawPhil →
- Heirs of Fedelina Sestoso Estella represented by Virgilia Estella Poliquit, et al. vs. Jesus, G.R. No. 245469, December 9, 2020 — read the decision on LawPhil →