AZNAR VS GARCIA

FACTS:
 Edward E. Christensen, though born in New York, 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. Counsel for appellant claims that California law should be applied; that under
California law, the matter is referred back to the law of the domicile; that therefore Philippine law is
ultimately applicable; that finally, the share of Helen must be increased in view of the successional rights
of illegitimate children under Philippine law. On the other hand, counsel for the heir of Christensen
contends that inasmuch as it is clear that under Article 16 of our Civil Code, the national law of the
deceased must apply, our courts must immediately apply the internal law of California on the matter;
that under California law there are no compulsory heirs and consequently a testator could dispose of
any property possessed by him in absolute dominion and that finally, illegitimate children not being
entitled to anything and his will remain undisturbed.
ISSUE:
 Whether or not the Philippine law should prevail in administering the estate of Christensen?
RULING:
 The court in deciding to grant more successional rights to Helen said in effect that there are two rules in
California on the matter: the internal law which should apply to Californians domiciled in California; and
the conflict rule which should apply to Californians domiciled outside of California.
The California conflict rule says: “If there is no law to the contrary in the place where personal property
is situated, is deemed to follow the person of its owner and is governed by the law of his
domicile.” Christensen being domiciled outside California, the law of his domicile, the Philippines,
ought to be followed. ART. 16. Real property as well as personal property is subject to the law of the
country where it is situated – (doctrine of lex rei sitae)