Aznar vs. Garcia, G.R.

L-16759, January 31, 1963

FATCS:

Edward E. Christensen the decedent was born in New York though 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.

Opposition to the approval of the project of partition was filed by Helen Christensen Garcia, insofar as it
deprives her (Helen) of her legitime as an acknowledged natural child, she having been declared by US in
G.R. Nos. L-11483-84 an acknowledged natural child of the deceased Edward E. Christensen.

Counsel for the acknowledged natural daughter Helen claims that under Article 16, par. 2 of the Civil
Code, California law should be should be applied; that under California law, the matter is referred back
to the law of the domicile.

On the other hand, the counsel for Maria Lucy Christensen contends that the national law of the
deceased must apply, illegitimate children not being entitled to anything under California law.

ISSUE:

Whether or not the Philippine law should apply in administering the estate of Edward E. Christensen?

HELD:

The court ruled applying renvoi doctrine, granting more successional rights to Helen, according to the
Supreme Court there are two rules in California on the matter: the internal law which applies to
California’s domiciled in California, and the conflict rule for Californian’s domiciled out of California.
Edward E. Christensen, being domiciled in the Philippines, the law of his domicile must be followed.

Because if it is referred back to California, it will form a circular pattern referring to both country back
and forth. For the determination of the successional rights under Philippine Law, the case was remanded
to the lower court for further proceedings.