3. Aznar vs. Garcia L-16749 G.R. No.

L-16749, 31 January 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; 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: Yes. 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.

However, intestate and testamentary successions, both with respect to the order of succession and to the
amount of successional rights and to the intrinsic validity of testamentary provisions, shall be regulated by the
national law of the person whose succession is under consideration, whatever may be the nature of the
property and regardless of the country where said property may be found.

There is no single American law governing the validity of testamentary provisions in the United States, each
state of the Union having its own private law applicable to its citizens only and in force only within the state.
The “national law” indicated in Article 16 of the Civil Code above quoted can not, therefore, possibly mean or
apply to any general American law. So it can refer to no other than the private law of the State of California.