7 SCRA 95 Civil Law Application of Laws Foreign Law Nationality Principle

Internal and Conflict Rule

Application of the Renvoi Doctrine
FACTS

Edward Christensen was born in New York but he migrated to California where he resided
for a period of 9 years. In 1913, he came to the Philippines where he became a domiciliary
until his death. In his will, he instituted an acknowledged natural daughter, Maria Lucy
Christensen (legitimate), as his only heir, but left a legacy sum of money in favor of Helen
Christensen Garcia (illegitimate). Adolfo Aznar was the executor of the estate. Counsel for
Helen claims that under Article 16, paragraph 2 of the Civil Code, California law should be
applied; that under California law, the matter is referred back to the law of the domicile. On
the other hand, counsel for Maria, averred that the national law of the deceased must apply,
illegitimate children not being entitled to anything under California law.
ISSUE:

Whether or not the national law of the deceased should be applied in determining the
successional rights of his heirs.

HELD:

The Supreme Court deciding to grant more successional rights to Helen said in effect that
there are two rules in California on the matter; the internal law which applies to Californians
domiciled in California and the conflict rule for Californians domiciled outside of California.
Christensen being domiciled in the Philippines, the law of his domicile must be followed.
The case was remanded to the lower court for further proceedings the determination of
the successional rights under Philippine law only.