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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 "