ESTATE ESTATE OF EDWARD E. CHRISTENSEN vs. HELEN CHRISTENSEN GARCIA, G.R. No.

L-
16749 January 31, 1963

IN THE MATTER OF THE TESTATE ESTATE OF EDWARD E. CHRISTENSEN, DECEASED.

ADOLFO C. AZNAR, Executor and LUCY CHRISTENSEN, Heir of the deceased, Executor and
Heir-appellees, VS. HELEN CHRISTENSEN GARCIA, oppositor-appellant
January 31, 1963

FACTS:

Edward E. Christensen, though born in New York, migrated to California, where he resided and
consequently was considered a California citizen. In 1913, he came to the Philippines where he became a
domiciliary until his death. However, during the entire period of his residence in this country he had always
considered himself a citizen of California. In his will executed on March 5, 1951, he instituted an
acknowledged natural daughter, Maria Lucy Christensen as his only heir, but left a legacy of sum of money
in favor of Helen Christensen Garcia who was rendered to have been declared acknowledged natural
daughter. Counsel for appellant claims that California law should be applied; that under California law, the
matter is referred back to the law of the domicile; that therefore Philippine law is ultimately applicable; that
finally, the share of Helen must be increased in view of the success ional rights of illegitimate children
under Philippine law. On the other hand, counsel for the heir of Christensen contends that inasmuch as it is
clear that under Article 16 of our Civil Code, the national law of the deceased must apply, our courts must
immediately apply the internal law of California on the matter; that under California law there are no
compulsory heirs and consequently a testator could dispose of any property possessed by him in absolute
dominion and that finally, illegitimate children not being entitled to anything and his will remain undisturbed.

ISSUE:
Whether or not the Philippine law should prevail in administering the estate of Christensen?

RULING:
The court in 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 should apply to Californians domiciled in California; and the
conflict rule which should apply to Californians domiciled outside of California. The California conflict rule
says: “If there is no law to the contrary in the place where personal property is situated, is deemed to follow
the person of its owner and is governed by the law of his domicile.” Christensen being domiciled outside
California, the law of his domicile, the Philippines, ought to be followed. Where it is referred back to
California, it will form a circular pattern referring to both country back and forth.