Short answer. Yes. The Civil Code requires the attestation to state the number of pages on which the will is written. It is one of three things the attestation must recite, alongside how the testator signed and how the witnesses signed in the presence of the testator and of one another.
What the law says
The attestation shall state the number of pages used upon which the will is written
Civil Code, Article 805 — Formalities of a Notarial Will. Read the full provision →
What the attestation has to recite
The article sets out the content of the attestation in one long sentence, and it contains three distinct statements. First, the number of pages used upon which the will is written. Second, that the testator signed the will and every page of it, or caused another person to write his name under his express direction, in the presence of the instrumental witnesses. Third, that those witnesses witnessed and signed the will and all its pages in the presence of the testator and of one another.
Why the page count is there at all
The page count is a safeguard against substitution. A will is usually several loose sheets, and sheets can be added or removed after execution without leaving an obvious trace. A stated number fixes the size of the document at the moment the witnesses attested to it, so a later count that does not match is visible on the face of the instrument. It works together with the marginal signatures on every page and the correlative numbering, all of which the same article requires.
The attestation is the witnesses' statement
It helps to keep straight who is speaking. The body of the will is the testator's; the attestation is what the witnesses declare about how the will was executed. That is why the recitals are about acts they observed — that the testator signed, that they signed in his presence and in one another's presence. The page count belongs in that declaration because the witnesses are the ones vouching for how much document was in front of them.
A related safeguard in the same article
The article closes with a rule aimed at attestations the witnesses cannot read: If the attestation clause is in a language not known to the witnesses, it shall be interpreted to them. The logic is the same as the page count. An attestation is only worth something if the people signing it understood what they were certifying. This is general information about what the Code requires of a notarial will, not advice about any particular 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 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 →