California and domiciled in the Philippines. Edward E. Christensen executed a will in Manila declaring Maria Lucy Christensen as his sole heir. The will also provides a devise of 3,600 in favor of Maria Helen Christensen, and stating among others that Maria Helen Christensen is not related to him. Opposition to the approval of the project of partition was filed by Helen Christensen Garcia, insofar as it deprives her (Helen) of her legitime as an acknowledged natural child. The legal grounds of the opposition are (a) that the distribution should be governed by the laws of the Philippines, and (b) that the distribution is contrary to law in so far as it denies to Helen Christensen, her legitime. The court ruled that as Edward E. Christensen was a citizen of the United States and of the State of California at the time of his death, the successional rights and intrinsic validity of the provisions in his will are to be governed by the law of California, in accordance with which a testator has the absolute right to dispose of his property in the way he desires. ISSUE: Is the will of Edward E. Christensen governed by the law of his national law (law of California)? HELD: NO. Applying the renvoi Ruling, the will of Edward E. Christensen is governed by the law of his domicile, the Philippines. The laws of California have prescribed two sets of laws for its citizens, one for residents therein and another for those domiciled in other jurisdictions. If we
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