Case Digest (G.R. No. 124518)
Facts:
In In the Matter of the Testate Estate of Edward E. Christensen, Deceased (117 Phil. 96, G.R. No. L-16749, January 31, 1963), the testator Edward E. Christensen executed his will on March 5, 1951 in Manila, naming his daughter Maria Lucy Christensen Daney as residuary legatee and bequeathing ₱3,600 to Helen Christensen Garcia, an acknowledged natural child. After Christensen’s death on April 30, 1953, Adolfo C. Aznar, executor, and Maria Lucy (appellees) filed final accounts and proposed partition in CFI Davao (Special Proc. No. 622). The lower court approved the accounts, ordered payment of ₱3,600 to Helen, and awarded the residue to Maria Lucy for life, with remainder interests in accordance with the will. Helen opposed the project, claiming Philippine succession law should apply to grant her one-half of the estate as forced heir under her acknowledged status. The trial court held that, as a U.S. citizen domiciled in the Philippines, the decedent’s succession was governed by CCase Digest (G.R. No. 124518)
Facts:
- Procedural Background
- Special Proceeding No. 622, CFI Davao: Executor Adolfo C. Aznar and heir Maria Lucy Christensen Daney filed final account.
- CFI approved account (Sept. 14, 1949), ordered reimbursement of P3,600 to Maria Lucy (paid to Helen) and awarded residue income to Maria Lucy for life, remainder to third parties per will.
- Decedent and Will Provisions
- Edward E. Christensen: born New York (1875), U.S./California citizen, long‐term resident and domiciliary in the Philippines, died Manila (April 30, 1953).
- Will (Mar. 5, 1951, Manila):
- Bequest of P3,600 in trust to Maria Helen Christensen Garcia (non‐relative acknowledged natural child) payable P100/month.
- Income of all residue to Maria Lucy Christensen Daney (only legitimate daughter) for life; remainder as provided.
- Opposition by Helen Christensen Garcia
- Helen previously declared acknowledged natural child by Supreme Court (G.R. Nos. L-11483-84).
- Grounds: estate governed by Philippine succession law; entitled as forced heir to one‐half of estate in full ownership.
- Lower Court Decision
- Applied California law (testator’s domicile state): upheld absolute testamentary freedom, denied legitime to Helen.
- Denied motions for reconsideration; appellant Helen Garcia appealed.
- Assignments of Error
- Ignoring Helen’s status as acknowledged natural child and her legitime.
- Failure to apply international law and renvoi doctrine.
- Erroneous reliance on California internal law over Philippine national law.
- Disregard of Philippine mandatory legitime provisions.
Issues:
- Which law governs intrinsic validity of the will: California internal law or Philippine national law under Civil Code, art. 16?
- Does California Civil Code, art. 946 (conflict‐of‐laws rule) apply, invoking the renvoi doctrine to refer succession to Philippine law?
- Is Helen entitled as an acknowledged natural child to her legitime under mandatory Philippine forced‐heirship rules?
- Did the lower court err in approving the executor’s distribution contrary to Philippine succession law?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)