In the Matter of the Estate of Edward E. Christensen vs. Adolfo C.

Aznar
GR No. L-16749

Facts:
The deceased, Edward Christensen, was recognized as citizen of California, died in the Philippines, it
being his domiciliary. He acknowledged his natural daughter Mary Lucy Christensen, as his only heir and
just left a legacy sum of money to Helen Christensen Garcia, who declared by SC, as acknowledged
daughter of the deceased. Counsel of Helen claims that under par. 2 of Article 16 of Civil Code, her share
must be increased in view of successional rights of illegitimate children under Philippine Law. The
counsel of Maria Lucy contends that the national law of the deceased shall prevail, stating that no
compulsory heirs and testator can disposed off his property by his absolute dominion, that his
illegitimate children are not entitled to such.

Issue:
Is the national law of California applicable?

Ruling:
The Supreme Court deciding to grant more successional rights to Helen Christensen Garcia said in effect
that there be two rules in California on the matter.

1.   The conflict rule which should apply to Californian’s outside the California, and
2.   The internal Law which should apply to California domiciles in California.

The California conflict rule, found on Art. 946 of the California Civil code States that “if there is no law to
the contrary in the place where personal property is situated, it is deemed to follow the decree of its
owner and is governed by the law of the domicile.”
Christensen being domiciled outside California, the law of his domicile, the Philippines is ought to be
followed.
Thus, the decision appealed is reversed and case is remanded to the lower court with
instructions that partition be made as that of the Philippine law provides.

Allison G. Gibbs vs. Government of the Philippine Islands