Case Digest (G.R. No. L-16749)
Facts:
In the Matter of the Testate Estate of Edward E. Christensen, Deceased; Adolfo C. Aznar, Executor and Lucy Christensen, Heir-Appellees, vs. Helen Christensen Garcia, Oppositor and Appellant, G.R. No. L-16749, January 31, 1963, the Supreme Court En Banc, Labrador, J., writing for the Court.The appeal arises from Special Proceeding No. 622 of the Court of First Instance of Davao, whose decision dated September 14, 1949 approved the executor’s final accounts and project of partition. The CFI ratified payment of P3,600 to Helen Christensen Garcia pursuant to the decedent’s will, ordered reimbursement to Maria (Lucy) Christensen of that amount, and directed that the residue of the estate be transferred to Lucy to enjoy during her lifetime, with further dispositions on her death in accordance with the will. The executor was Adolfo C. Aznar; Lucy Christensen (Mrs. Bernard Daney) and Aznar were appellees below; Helen was oppositor and appealed.
The will (executed in Manila on March 5, 1951) named Lucy as the only child and residuary legatee and expressly bequeathed P3,600 to Helen to be held in trust and paid at P100 per month. The executor admitted those dispositions in his final account and proposed distribution in accordance with the will. Helen opposed the project of partition, asserting that she had previously been judicially declared an acknowledged natural child of Edward E. Christensen in G.R. Nos. L-11483-84, that Philippine succession law (and not California law) should govern distribution, and that as an acknowledged natural child she was entitled to her legitime (one-half of the estate) under Philippine law.
At the CFI the executor and appellees argued that the decedent was a citizen of the United States and of California at death and therefore the intrinsic validity of his testamentary dispositions was governed by California law; the court accepted this position, citing California authorities such as In re McDaniel’s Estate and In re Kaufman. Motions for reconsideration filed by Helen were denied, and she appealed to the Supreme Court.
The parties contested the decedent’s domicile and citizenship. The record showed Edward E. Christensen was born in New York (November 29, 1875), lived in Sacramento, California (1904–1913), first arrived in the Philippines in 1901 and thereafter...(Pro-only)
Issues:
- Should the intrinsic validity of Edward E. Christensen’s testamentary dispositions be governed by the internal law of the State of California or by Philippine law?
- If Philippine law governs, is appellant Helen Christensen Garcia, as an acknowledged natural child, entitled to her legitime under P...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)