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 which he executed here in the Philippines, 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 (according to his will, not related to him). Adolfo Aznar was the executor of the estate and after complying with the terms of the will, he submitted to the court the approval of said will. Helen filed an opposition on the ground that she is being deprived of her legitime especially considering that the Supreme Court, in a decided case, declared her as an acknowledged illegitimate heir of Edward – hence, to her, the will is void. Aznar and Maria Lucy objected to the opposition. Aznar and Maria argued that the validity of the will should be determined under California Law and that under said law, illegitimate children are not entitled to anything. On the contrary, counsel for Helen claims that in determining the validity of the will, Philippine Laws should be applied because the same is provided for by the California Law itself for cases wherein the decedent is domiciled outside California at the time of his/her death.
ISSUE: Whether or not Philippine Laws should be applied in the instant case.
HELD: Yes. Philippine Law shall apply in the instant case. Hence, the case is remanded to the lower court for the determination of the validity of the will. A close reading of the California Law on successional rights reveal that the law has two aspects: the internal law which applies to Californians domiciled in California at the time of their death and the conflict rule for Californians domiciled outside of California at the time of their death. Edward Christensen at the time of his death was undeniably a US/California citizen domiciled in the Philippines, hence, the law of his domicile, the Philippines, must be followed. In coming up with this ruling, the Supreme Court made use of the renvoi doctrine: The recognition of the renvoi theory implies that the rules of the conflict of laws are to be understood as incorporating not only the ordinary or internal law of the foreign state or country, but its rules of the conflict of laws as well. According to this theory ‘the law of a country’ means the whole of its law.
