G.R. No. L-16749, January 31, 1963
Edward E. Christensen was a citizen of the United States and of the State of California but was domiciled in the Philippines at the time of his death. In accordance with the provisions of the will of the testator, the estate shall be distributed, which provides Php 3,600 be given to HELEN Christensen and the rest of his estate to his daughter LUCY Christensen.
Helen filed an opposition insofar as it deprives her of her legitime as an acknowledged natural child under the laws of the Philippines. She insisted that Article 946, California Civil Code should be applicable following the doctrine of renvoi – “if there is no law to the contrary in the place where personal property is situated, it is deemed to follow the decree of its owner and is governed by the law of the domicile”.