ESTATE OF CHRISTENSEN

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.
- The theory in the Renvoi Doctrine is applicable in this case.
- The theory of the doctrine of renvoi is that the court of the forum, in determining the question before it, must
take into account the whole law of the other jurisdiction, but also its rules as to conflict of laws, and then
apply the law to the actual question which the rules of the other jurisdiction prescribe.
- 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 the country means the whole of its laws.

FACTS:
-Edward E. Christensen executed a will declaring Maria Lucy Christensen (now Mrs. Bernard Daney) entitled to the residue of
his property after depositing a sum of three thousand six hundred pesos to the account of Maria Helen Christensen whom he
declared is not in any way related to him nor adopted by him. Maria Helen Christensen averred that she was an acknowledged
natural child in the United States and the will of Edward deprives her of her legitime (one half of the estate in full ownership)

ISSUE: What law should govern the instant case, the California or the Philippine law?

HELD:
-The SC held that insofar as Maria Helen Christensen is concerned, it is the Philippine law that should govern. The domicile of
the deceased is the Philippines although he is a citizen of California. The validity of the provisions of his will depriving his
acknowledged natural child should be governed by the Philippine law pursuant to Art. 946 of the Civil Code of California not by
internal law of California.

Facts: Edward Christensen, American Citizen residing in Davao was the manager of the Mindanao Estates. During his stay, he met Bernada
Compredora, wherein they lived as husband and wife without being married. During their cohabitation for 30 years, they bore 2 daughters
namely Maria Lucy and Maria Helen. When Edward died he left a will containing: 1) Maria Lucy is his only daughter to which he gave all his
properties and income; 2) Maria Helen, who is not her daughter, but uses his surname and alleged to be the offspring of Bernada with
another man, giving her trust fund of P3,600.00; 3) Bernada was given P1,000.00 and 4) Adolfo Cruz Aznan as executor.

Maria Helen and Bernada opposed the said will, wherein the former contended that she was a natural child and therefore must be entitled
to the said properties, the latter however contended that although they were not married, they cohabited for 30 years, therefore she should
be given ½ of the said properties because of co-ownership.

Issue: whether Bernada is entitled to ½ of the state under the law on co-ownership?

Held: No, Bernada is not entitled to ½ of the properties. Before the Civil Code went into operation, the court already decided, that when a
man and a woman, not suffering from any impediment to contract marriage, lived together as husband and wife, an informal civil
partnership exist, and each of them has an equal interest in the properties acquired during said union and is entitled to participate therein
said properties were the product of their joint effort.

In the case at bar, aside from the observation of the trial court that Bernada was an illiterate woman, there appears no evidence to prove
her contributions or participation in the acquisition of the properties involved, therefore following the aforecited ruling the claim of ½ of the
properties cannot be granted. Even assuming for the sake of argument that this case falls under the provisions of Article 144 of the Civil
Code which recognizes the parties as co-owners of the properties acquired after the act concerned and to no other, for such law cannot be
given retroactive effect to govern those already possessed before August 30, 1950.