AZNAR v.

GARCIA

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.

HELD: The Supreme Court deciding to grant more successional rights to Helen said in effect that there are two rules in California on
the matter; the internal law which applies to Californians domiciled in California and the conflict rule for Californians domiciled
outside of California. Christensen being domiciled in the Philippines, the law of his domicile must be followed. The case was
remanded to the lower court for further proceedings the determination of the successional rights under Philippine law only.

Where the testator was a citizen of California, and domiciled in the Philippines, the amount of successional rights should be governed
by his national law. However, since the conflicts of law rules of California provides that in case of citizens who are residents of
another country, the law of the country of domicile should apply, then Philippine law on legitimes was applied. Hence, under
Philippine laws, the acknowledged natural daughter cannot be deprived of her legitime.

HONGKONG SHANGAI BANKING CORPORATION v. SHERMAN
G.R. No. 72494 August 11, 1989


FACTS: In 1981, Eastern Book Supply Service PTE, Ltd., (Eastern) a company incorporated in Singapore applied w/, & was granted
by the Singapore branch of HSBC an overdraft facility in the max amount of Singapore $200,000 (w/c amount was subsequently
increased to Singapore $375,000) w/ interest at 3% over HSBC prime rate, payable monthly, on amounts due under said overdraft
facility. As a security for the repayment by Eastern of sums advanced by HSBC to it through the aforesaid overdraft facility, in 1982,
Jack Sherman, Dodato Reloj, and a Robin de Clive Lowe, all of whom were directors of Eastern at such time, executed a Joint and
Several Guarantee in favor of HSBC whereby Sherman, Reloj and Lowe agreed to pay, jointly and severally, on demand all sums
owed by Eastern to HSBC under the aforestated overdraft facility.

The Joint and Several Guarantee provides that: This guarantee and all rights, obligations and liabilities arising hereunder shall be
construed and determined under and may be enforced in accordance with the laws of the Republic of Singapore. We hereby agree
that the Courts of Singapore shall have jurisdiction over all disputes arising under this guarantee.

Eastern failed to pay its obligation. Thus, HSBC demanded payment of the obligation from Sherman & Reloj, conformably w/ the
provisions of the Joint and Several Guarantee. Inasmuch as Sherman & Reloj still failed to pay, HSBC filed a complaint for collection
of a sum of money against them. Sherman & Reloj filed a motion to dismiss on the grounds that (1) the court has no jurisdiction
over the subject matter of the complaint, and (2) the court has no jurisdiction over the person of the defendants.

ISSUE: W/N Philippine courts should have jurisdiction over the suit.

RULING: YES. While it is true that "the transaction took place in Singaporean setting" and that the Joint and Several Guarantee
contains a choice-of-forum clause, the very essence of due process dictates that the stipulation that "this guarantee and all rights,
obligations & liabilities arising hereunder shall be construed & determined under & may be enforced in accordance w/ the laws of the
Republic of Singapore. We hereby agree that the Courts in Singapore shall have jurisdiction over all disputes arising under this
guarantee" be liberally construed. One basic principle underlies all rules of jurisdiction in International Law: a State does not have
jurisdiction in the absence of some reasonable basis for exercising it, whether the proceedings are in rem quasi in rem or in
personam. To be reasonable, the jurisdiction must be based on some minimum contacts that will not offend traditional notions of fair
play and substantial justice. Indeed, as pointed-out by HSBC at the outset, the instant case presents a very odd situation. In the
ordinary habits of life, anyone would be disinclined to litigate before a foreign tribunal, w/ more reason as a defendant. However, in
this case, Sherman & Reloj are Philippine residents (a fact which was not disputed by them) who would rather face a complaint
against them before a foreign court and in the process incur considerable expenses, not to mention inconvenience, than to have a
Philippine court try and resolve the case. Their stance is hardly comprehensible, unless their ultimate intent is to evade, or at least
delay, the payment of a just obligation.

The defense of Sherman & Reloj that the complaint should have been filed in Singapore is based merely on technicality. They did not
even claim, much less prove, that the filing of the action here will cause them any unnecessary trouble, damage, or expense. On the
other hand, there is no showing that petitioner BANK filed the action here just to harass Sherman & Reloj.

The parties did not thereby stipulate that only the courts of Singapore, to the exclusion of all the rest, has jurisdiction. Neither did
the clause in question operate to divest Philippine courts of jurisdiction. In International Law, jurisdiction is often defined as the light
of a State to exercise authority over persons and things w/in its boundaries subject to certain exceptions. Thus, a State does not
assume jurisdiction over travelling sovereigns, ambassadors and diplomatic representatives of other States, and foreign military
units stationed in or marching through State territory w/ the permission of the latter's authorities. This authority, which finds its
source in the concept of sovereignty, is exclusive w/in and throughout the domain of the State. A State is competent to take hold of
any judicial matter it sees fit by making its courts and agencies assume jurisdiction over all kinds of cases brought before them.