Short answer. Yes, in substance. The law does not demand full possession of all his reasoning faculties, but it does require that he was able, when he made the will, to know the proper objects of his bounty — the people who would naturally be expected to benefit, such as close relatives.
What the law says
It shall be sufficient if the testator was able at the time of making the will to know the nature of the estate to be disposed of, the proper objects of his bounty, and the character of the testamentary act
Civil Code, Article 799 — What 'Sound Mind' Means. Read the full provision →
The bar is lower than 'full mental faculties'
The law is explicit that soundness of mind does not require a testator to be in full possession of all his reasoning faculties, or that his mind be wholly unbroken, unimpaired, or unshattered by disease, injury, or other cause. Someone recovering from illness, dealing with age-related decline, or otherwise not at their sharpest can still be of sound mind for purposes of making a will — the standard is deliberately more modest than perfect mental clarity.
What the law asks for instead
In place of full mental faculties, it is enough that the testator was able, at the time of making the will, to know three specific things: the nature of the estate being disposed of, the proper objects of his bounty, and the character of the testamentary act itself. Knowing the proper objects of his bounty is where your question about close relatives fits — it means being aware of the people who would ordinarily be expected to receive from him.
Why 'proper objects of his bounty' matters here
This element does not require your father to have recited every relative's name from memory. It asks whether he had a working awareness of who his close family was and who would naturally be considered in disposing of his estate. A testator who genuinely could not identify or recognize his own children or spouse at the relevant time would be missing exactly the kind of awareness this element is meant to capture.
All three elements have to be present together
Knowing the proper objects of his bounty is only one of three things the law requires — the testator must also have understood the nature of the estate being disposed of and the character of the testamentary act itself. A will is not automatically valid just because one element is satisfied; the question is whether, taken together, he had the awareness the statute describes when he actually signed.
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.
- Spouses Isidro Dulay III and Elena Dulay vs. People of the Philippines, G.R. No. 215132, September 13, 2021 — read the decision on LawPhil →
- Antonio Baltazar, et al. vs. Lorenzo Laxa, G.R. No. 174489, April 11, 2012 — read the decision on LawPhil →
- 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 →