acts:

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. On the other hand,
counsel for daughter Maria , in as much
that it is clear under Art, 16 (2) of the Mew
Civil Code, the national of the deceased
must apply, our courts must apply internal
law of California on the matter. Under
California law, there are no compulsory
heirs and consequently a testator should
dispose any property possessed by him in
absolute dominion.

Issue:

Whether Philippine Law or

California Law should apply.

Held:

The Supreme Court deciding to

grant more successional rights to Helen
Christensen Garcia said in effect that there
be two rules in California on the matter.

1. The conflict rule which should

 apply to Californian’s outside the
California, and

2. The internal Law which should

apply to California domiciles in
califronia.

The California conflict rule, found on

Art. 946 of the California Civil code States
that “if there is no law to the contrary in
the place where personal property is
situated, it is deemed to follow the decree
of its owner and is governed by the law of
the domicile.”

Christensen being domiciled outside

california, the law of his domicile, the
Philippines is ought to be followed.

Wherefore, the decision appealed is

reversed and case is remanded to the
lower court with instructions that
partition be made as that of the
Philippine law provides.