Ramirez v gmur

 Facts
o Bischoff is swiss and RP-res
o Bischoff died with will saying he has no forced heirs
o He has natural daughter with 2 sets of natural children
o Natural daughter had two british lovers
o First set of children born from Kauffman who divorced Leona in france
o Second set from mory. Their rights depend on divorce decree
 French courts have no JD over dissolution of marriage over pinoys because they cannot divorce
 Not domiciled = no JD to determine matrimonial status
 Second marriage void. Illegit children cannot inherit from grandpa