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Aznar vs Garcia Facts: Helen Christensen Garcia filed a petition for review to the Supreme Court the decision

of the lower court in Davao declaring that Maria Luc Christensen is the sole heir of testator !dward Christensen" Facts of the case are as follows: #" !dward Christensen was $orn in %ew &or' $ut he migrated to California where he resided for a period of ( ears" )" He came to the *hilippines where he $ecame a domiciliar until his death" +" ,n his will- he declared to have onl one child .natural daughter/ Maria Luc Christensen as his onl heir 0" However- he left a sum of mone in favor of Helen Christensen Garcia- an ac'nowledged natural child- though not in an wa related to the deceased" 1" Helen claims that under Article #2- paragraph ) of the Civil Code- California law should $e applied3 that under California law- the matter is referred $ac' to the law of the domicile" ,SS4!: 5hether or not the national law of the deceased should $e applied in determining the successional rights of his heirs" H!LD: &es" Article #2 of the Civil Code states that succesional rights are determined $ the national law of the countr where the deceased is a citizen hence the internal law of California since it was ruled that !dward Christensen is a citizen of California" Said internal law distinguishes the rule to $e applied to Californians domiciled in California and for Californians domiciled outside of California" For Californians residing in other 6urisdiction- the law of said countr must appl " !dward Christensen $eing domiciled in the *hilippines- the law of his domicile must $e followed" 7he case was remanded to the lower court for further proceedings 8 the determination of the successional rights under *hilippine law onl "

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