Aznar vs Garcia

Facts:

Helen Christensen Garcia filed a petition for review to the Supreme Court the decision of the
lower court in Davao declaring that Maria Lucy Christensen is the sole heir of testator Edward
Christensen. Facts of the case are as follows:

1. Edward Christensen was born in New York but he migrated to California where he
resided for a period of 9 years.
2. He came to the Philippines where he became a domiciliary until his death.
3. In his will, he declared to have only one child (natural daughter) Maria Lucy Christensen
as his only heir
4. However, he left a sum of money in favor of Helen Christensen Garcia, an acknowledged
natural child, though not in any way related to the deceased.
5. 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.

ISSUE:

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

HELD:
Yes. Article 16 of the Civil Code states that succesional rights are determined by the national law
of the country where the deceased is a citizen hence the internal law of California since it was
ruled that Edward Christensen is a citizen of California.

Said internal law distinguishes the rule to be applied to Californians domiciled in California and for
Californians domiciled outside of California. For Californians residing in other jurisdiction, the law
of said country must apply. Edward 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.