IN THE MATTER OF THE TESTATE ESTATE OF EDWARD E.

CHRISTENSEN, DECEASED.ADOLFO C. AZNAR, Executor and LUCY

CHRISTENSEN, Heir of the deceased, Executor and Heir-appellees,
VS. HELEN CHRISTENSEN GARCIA, oppositor-appellant January 31,
1963
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; hat 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. Where it is referred back to California, it will form a
circular pattern referring to both country back and forth.