Adolfo C. Aznar v.

Helen Christensen Garcia

G.R. No. L-16749, January 31, 1963

LABRADOR, J.

FACTS:

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.

ISSUE/S: Whether or not the succession is governed by Philippine laws.

RULING/S: YES. Philippine law governs.

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 legitimes must be respected.