Estate of Boyajian

Holding

The court held that (1) revocation of a will by “cancellation” under Probate Code § 6120(b) requires a physical act performed on the will itself, and (2) a stand‑alone document that merely expresses intent to revoke does not constitute a “subsequent will” under § 6120(a) because it lacks testamentary intent, a beneficiary designation, and the statutory witnessing formalities. Accordingly, the 2018 document could not revoke the 2006 holographic will, and the trial court’s finding of undue influence was affirmed. ---