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Edward S. Christensen, though born in New York, migrated to California where he resided and consequently was
considered a California Citizen for a period of nine years to 1913. He came to the Philippines where he became a
domiciliary until the time of his death. However, during the entire period of his residence in this country, he had
always considered himself as 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 some money in favor of Helen Christensen Garcia who, in a decision rendered by
the Supreme Court had been declared as an acknowledged natural daughter of his. Counsel of Helen claims that
under Art. 16 (2) of the civil code, California law should be applied, the matter is returned back to the law of
domicile, that Philippine law is ultimately applicable, that the share of Helen must be increased in view of
successional rights of illegitimate children under Philippine laws. On the other hand, counsel for daughter Maria , in
as much that it is clear under Art, 16 (2) of the Mew Civil Code, the national of the deceased must apply, our courts
must apply internal law of California on the matter. Under California law, there are no compulsory heirs and
consequently a testator should dispose any property possessed by him in absolute dominion.

ISSUE: Whether Philippine Law or California Law should apply.

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 Californians outside the California, and
2. The internal Law which should apply to California domiciles in califronia.
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.
Wherefore, 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.

*Article 16 of the Civil Code provides that the intrinsic validity of testamentary dispositions are governed by the
national law of the decedent, in this case, California law. The provision in the laws of California giving a testator
absolute freedom in disposing of his estate is the internal law which applies only to persons domiciled within the
said estate. On the other hand, the provision in the laws of California stating that personal property is governed by
the laws of the domicile of its owner is the conflict of laws rule that applies to persons not domicile in the said
state. Accordingly, the laws of the Philippines, in which the testator is domiciled governs the succession and the
regime of legitime must be respected.