FACTS:

Gerbert R. Corpuz, a former Filipino citizen,  who acquired Canadian citizenship through naturalization married Daisylyn Sto. Tomas. When he found that his wife was having an affair, Gerbert filed a petition for divorce in Canada; and was granted. 

After 2 years, Gerbert found a new love and decided to marry. He then filed a petition for judicial recognition of foreign divorce and/or declaration of marriage as dissolved. RTC denied the petition and concluded that Gerbert was not the proper party to institute the action for judicial recognition of the foreign divorce decree as he is a naturalized Canadian citizen.  It ruled that only the Filipino spouse can avail of the remedy, under the second paragraph of Article 26 of the Family Code, in order for him or her to be able to remarry under Philippine law.

Gerbert considers himself as a proper party, vested with sufficient legal interest, to institute the case, as there is a possibility that he might be prosecuted for bigamy if he marries his Filipina fiancée in the Philippines since two marriage certificates, involving him, would be on file with the Civil Registry Office.

FACTS:

Cipriano Orbecido III married Lady Myros M. Villanueva at the United Church of Christ in the Philippines in Lam-an, Ozamis City. Their marriage was blessed with a son and a daughter.

Myros left for the United States bringing along their son Kristoffer. She had been naturalized as an American citizen, obtained divorce decree and married a certain Innocent Stanley.

Cipriano thereafter filed with the trial court a petition for authority to remarry invoking Paragraph 2 of Article 26 of the Family Code. The Republic, herein petitioner, through the Office of the Solicitor General (OSG), sought reconsideration but it was denied.

FACTS:

Testator Bohonan, a citizen of the State of Nevada at the time of his death declares that his will and testament shall be governed by the laws of the state of Nevada and admits the same to probate.  Out  of the total estate of P211,639.33 in cash, the testator gave his grandson P90,819.67 and one-half of all shares of stock of several mining companies and to his brother and sister the same amount. To his children he gave a legacy of only P6,000 each, or a total of P12,000.

The wife Magdalena C. Bohanan and her two children question the validity of the testamentary provisions disposing of the estate in the manner above indicated, claiming that they have been deprived of the legitime that the laws of the forum concede to them. It is not disputed that the laws of Nevada allow a testator to dispose of all his properties by will.

G.R. No. L-16749, January 31, 1963

FACTS:

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”.