Edward E. Christensen, an American citizen from California and domiciled in the Philippines, left a will executed in the Philippines in which he bequeathed Php 3,600.00 to Maria Helen Christensen ("Helen") and the remainder of his estate to his daughter, Maria Lucy Christensen Daney. The laws of California allows the testator to dispose of his estate in any manner he pleases. However, California law also provides that the personal property of a person is governed by the laws of his domicile. The executor, Adolfo C. Aznar, drew a project of partition in conformity with the will. Helen opposed the project of partition arguing that Philippine laws govern the distribution of the estate and manner proposed in the project deprived her of her legitime.
Issue
Whether or not the succession is governed by Philippine laws.
Held
Yes. Philippine law governs.
Ratio
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.
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