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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- Fall '19
- Law, Common Law, HELEN CHRISTENSEN GARCIA, Edward E. Christensen, MARIA HELEN CHRISTENSEN
