RENVOI

PHILIPPINE COMMERCIAL AND INDUSTRIAL BANK vs. ESCOLIN

G.R. No. L-27860
March 29, 1974
Facts:
Linnie Jane Hodges, a married woman and a citizen of Texas, USA, was a
domiciliary of the Philippines at the moment of her death. With respect to the validity of
certain testamentary provisions she had made in favor of her husband, a question arose
as to what exactly were the laws of Texas on the matter at the precise moment of her
death (for while one group contended that the Texan law should result to renvoi, the
other group contended that no renvoi was possible).
Issue:

Whether or not Texas Law should apply.

Ruling:
The Supreme Court held that for what the Texas law is on the matter, is a
question of fact to be resolved by the evidence that would be presented in the probate
court. Texas law at the time of her death (and not said law at any other time).