Title
Philippine Trust Co. vs. Boha
Case
G.R. No. L-12105
Decision Date
Jan 30, 1960
A U.S. citizen's will, governed by Nevada law, was upheld in the Philippines despite claims by his former wife and children for legitime under Philippine law, as the divorce and will were valid under Nevada law.
A

Case Summary (G.R. No. 224673)

Petitioner / Respondent Designation and Procedural Posture

Appellants: Magdalena C. Bohanan and her two children (Mary Lydia and Edward) who opposed the executor’s project of partition. Appellee: Philippine Trust Company as executor. The probate court admitted the will and appointed the executor; later the executor filed a project of partition which the trial court approved. The appellants filed objections to the partition that were dismissed by the trial court; the dismissal was appealed.

Key Dates (pertinent to facts and procedure)

Will executed: April 23, 1944 (in Manila). Probate order admitting the will and appointing executor: April 24, 1950. Executor’s project of partition filed: January 24, 1956. Earlier intermediate proceedings relevant to appellants’ claims occurred in 1953–1955 (e.g., motion to withdraw P20,000 and an order dated June 18, 1955).

Applicable Law and Evidentiary Rules Cited

  • Old Civil Code: par. 2, Art. 10 (governing the national law applicable to the order and extent of successional rights).
  • Nevada Compiled Laws of 1925, Sec. 9905 (providing that every person over eighteen of sound mind may by will dispose of all his or her estate).
  • Rules regarding proof of foreign law (quoted as Sec. 41, Rule 123 in the record) addressing admissibility of official foreign records or certified copies.

Facts: Will’s Dispositions and Estate Composition

After administration expenses, the estate amounted to P211,639.33 in cash plus shares of several mining companies. The will adjudicated: one-half of the residuary estate (P90,819.67 cash and one-half of the stocks) to the Los Angeles bank in trust for testator’s grandson; the other half to the testator’s brother and sister (in like amounts); legacies of P6,000 each to the testator’s son Edward Gilbert and daughter Mary Lydia; additional legacies to named individuals (Clara Daen P10,000; Katherine Woodward P2,000; Beulah Fox P4,000; Elizabeth Hastings P2,000). The appellants contended these dispositions deprived them of their legitime under Philippine law.

Procedural Findings Below Bearing on Claims

The probate court found that the testator was a citizen of the United States and of the State of Nevada, having selected Nevada as his domicile and permanent residence. The lower court also found that a divorce obtained by the testator (a “Reno” divorce) had been recognized and that there was no conjugal/community property between the testator and Magdalena at the time of the divorce. The court further made a prior final order (June 18, 1955) adverse to Magdalena’s claim, a ruling she did not appeal.

Issues Presented

  1. Whether the former wife, Magdalena, was entitled to a share of the estate under Philippine succession law despite the Reno divorce and alleged absence of community property.
  2. Whether the testator’s children (Edward and Mary Lydia) were entitled to their legitime under Philippine law (asserting they should receive two-thirds of the estate) despite the will’s smaller legacies.
  3. Whether the testamentary dispositions are valid when governed by the testator’s national law (Nevada law) permitting full testamentary disposition.

Legal Analysis on Nationality, Domicile and Applicable Succession Law

Under the old Civil Code provision invoked (par. 2, Art. 10), testamentary succession (order and extent of successional rights and intrinsic validity) is governed by the national law of the person whose succession is in question. The probate court’s finding that the testator had selected Nevada as his domicile determined his national law for succession purposes. Because Nevada law (Sec. 9905) permits a testator to dispose of all property by will, the validity and extent of dispositions are governed by that law rather than Philippine forced heirship norms, if the testator’s national law is indeed Nevada.

Proof and Judicial Notice of Foreign Law

Although foreign law must ordinarily be proved according to the applicable rules (official records, certified copies, etc.), the Supreme Court found that Section 9905 of the Nevada law had been placed in evidence during earlier proceedings (introduced as Exhibit “2” by appellants’ counsel in the 1954 hearing and as Exhibit “B” by the executor in the 1950 probate hearing). The Court therefore held that the pertinent Nevada law could be taken judicial notice of in the present proceedings without fresh proof at the partition hearing, particularly because the provision was not disputed by appellants.

Effect of Reno Divorce and Community Property Finding on Widow’s Claim

The trial court’s findings that (a) divorce had been granted to the testator, (b) Magdal

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