Short answer. Yes, it generally needs to be reprobated. A will proved and allowed in a foreign country, according to that country's laws, may be allowed, filed, and recorded by the proper Philippine trial court, which then gives it the same effect as a will originally probated there.
What the law says
Wills proved and allowed in a foreign country, according to the laws of such country, may be allowed, filed, and recorded by the proper Court of First Instance in the Philippines.
Rule 77, Section 1 — Will proved outside Philippines may be allowed here. Read the full provision →
What the law says
If it appears at the hearing that the will should be allowed in the Philippines, the court shall so allow it, and a certificate of its allowance, signed by the judge, and attested by the seal of the court, to which shall be attached a copy of the will, shall be filed and recorded by the clerk, and the will shall have the same effect as if originally proved and allowed in such court.
Rule 77, Section 3 — When will allowed, and effect thereof. Read the full provision →
Foreign probate is recognized, but through this local process
The rule allows a will proved and allowed in a foreign country, according to the laws of such country, to be allowed, filed, and recorded by the appropriate Philippine trial court. Foreign probate is not simply ignored — it is the starting point this rule recognizes — but it still has to be brought before a Philippine court through this reprobate process.
A hearing decides whether the will should be allowed here too
The Philippine proceeding is not a rubber stamp. The rule provides that if it appears at the hearing that the will should be allowed in the Philippines, the court shall so allow it. There is a genuine hearing at which the Philippine court examines the matter before extending recognition to the foreign probate already obtained.
This examination is what gives the reprobate proceeding real substance, rather than treating it as a purely clerical formality.
Once allowed here, the will has full local effect
Once the Philippine court allows the will, it issues a certificate of its allowance, signed by the judge, and attested by the seal of the court, with a copy of the will attached, filed and recorded by the clerk. From that point, the will shall have the same effect as if originally proved and allowed in such court — full local legal effect, not merely a foreign document being referenced.
Why this reprobate step matters for heirs and executors
A will probated abroad does not automatically carry legal force for property or matters located in the Philippines. Anyone relying on a foreign-probated will to settle a Philippine estate should expect to go through this reprobate proceeding, rather than assuming the foreign court's decision alone is sufficient for dealing with assets or heirs within the country itself.
Planning for this extra step early can save considerable time when a Philippine estate is involved alongside a foreign one.
Related provisions
- Rule 77, Section 1 — Will proved outside Philippines may be allowed here
- Rule 77, Section 3 — When will allowed, and effect thereof