Aznar vs. Garcia [7 SCRA 95]

Facts: Edward Christensen’s (citizen of the State of California) will was executed in Manila where it provides that Helen Christensen Garcia receive a payment of P3,600 and proposed that the residue of the estate be transferred to his daughter Maria Lucy Christensen. Helen Christensen Garcia opposed the project of partition of Edward’s estate claiming that she was deprived of her legitime as acknowledged natural child under the Philippine law. 

Issue: Whether or not the California law or the Philippine law should apply in the case at bar. 

Held: Philippine law should be applied. The State of California prescribes two sets of laws for its citizens residing therein and a conflict of law rules for its citizens domiciled in other jurisdictions. 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 person of its owner and is governed by the law of his domicile.” Edward, a citizen of the State of California, is considered to have his domicile in the Philippines. The court of domicile cannot and should not refer the case back to the California, as such action would leave the issue incapable of determination, because the case would then be tossed back and forth between the states(doctrine of renvoi). The validity of the provisions of Edward’s will depriving his acknowledged natural child of latter’s legacy, should be governed by the Philippine law. 

The decision appealed from is reversed and the case returned to the lower court with instruction that the partition be made as the Philippine law on succession provides.