Aznar v Garcia

FACTS:
Edward, a US citizen (California), domiciled in Phil upon death (domiciled in Phil and occasionally returned to Cal; but,
remained a US citizen), executed his last will in Phil (Lucy as only descendant; legacy of P3,600 to Helen and remainder to Lucy).
Helen argued that she was a natural child and Phil law must be applied which entitles her to 1/2 of the legitimes.
ISSUE:
W/N Phil law should apply.
HELD:
YES. First, case was filed in Phil involving property in Phil. Second, Art 16 of CC states that successional rights are determined by
the nationality of the person, regardless of nature and where property is located. Third, Art 946 of Cal law states that law of domicile
is followed. Fourth, proponents of the "doctrine of renvoi" state that the point of reference is the foreign law which then points back
to the application of the domestic law . Opponents of renvoi argue that the point of reference is the domestic law and thus, the
foreign law should be applied. Both are consistent with the need to resolve an endless chain of references. Thus, in this case
(applying renvoi), Phil law refers to Cal law, Cal law refers to Phil law, and thus, Phil law should be applied (court of domicile should
not refer case back to Cal). Helen is a forced heir as an acknowledged natural child.