Philippine Supreme Court Decisions Digests

PHILIPPINE COMMERCIAL AND INDUSTRIAL BANK vs. ESCOLIN G.R. No. L-27860, March 29, 1974  Facts Linnie Jane Hodges, a married woman and a citizen of Texas, USA, was a domiciliary of the Philippines at the moment of her death. With respect to the validity of certain testamentary provisions she had made in favor of her husband, a question arose as to what exactly were the laws of Texas on the matter at the precise moment of her death (for while one group contended that the Texan law should result to renvoi, the other group contended that no renvoi was possible).  Issue Whether or not Texas Law should apply.  Ruling The Supreme Court held that for what the Texas law is on the matter, is a question of fact to be resolved by the evidence that would be presented in the probate court. Texas law at the time of her death (and not said law at any other time).  

BELLIS vs. BELLIS G.R. No. L-23678, June 6, 1967  Facts Amos Bellis was a citizen of the State of Texas, and of the United States. By his first wife whom he divorced he had five legitimate children, by his second wife, who survived him, he had three legitimate children, and three illegitimate children. Before he died, he made two wills, one disposing of his Texas properties and the other disposing his Philippine properties. In both wills, his illegitimate children were not given anything. The illegitimate children opposed the will on the ground that they have been deprived of their legitimates to which they should be entitled, if Philippine law were to be applied.  Issue Whether or not the national law of the deceased should determine the successional rights of the illegitimate children.  Ruling The Supreme Court held that the said children are not entitled to their legitimes under the Texas Law, being the national law of the deceased, there are...

AZNAR vs. GARCIA G.R. No. L-16749, January 31, 1963  Facts Edward Christensen was born in New York but he migrated to California where he resided for a period of 9 years. In 1913, he came to the Philippines where he became a domiciliary until his death. In his will, he instituted an acknowledged natural daughter, Maria Lucy Christensen (legitimate), as his only heir, but left a legacy sum of money in favor of Helen Christensen Garcia (illegitimate). Counsel for Helen claims that under Article 16, paragraph 2 of the Civil Code, California law should be applied; that under California law, the matter is referred back to the law of the domicile. On the other hand, counsel for Maria, averred that the national law of the deceased must apply, illegitimate children not being entitled to anything under California law.  Issue Whether or not the national law of the deceased should be applied in determining the successional rights of his heirs.  Ruling The ...