Bellis vs. Bellis G.R. No.

L-23678

Facts: The decedent was a citizen and domicile of Texas, United States. Under the laws of Texas, there are no compulsory heirs
or legitime. Before he died, he executed a will in the Philippines. The will stated that his legitimate children will get the
remainder of his estate. In the probate proceeding the illegitimate children opposed on the ground that they were deprived of
their legitime as the compulsory heirs of the deceased. They argued that the decedent intended in his will that his properties in
the Philippine should be distributed in accordance with Philippine law not his national law.

Issue: Whether or not the Philippine law on legitime will be applied to the testacy of the decedent.

Ruling: NO. Under article 16, par. 2 of the Civil Code, the national law of the decedent applies, in intestate or testamentary
successions, with regard to four items: (a) the order of succession; (b) the amount of successional rights; (e) the intrinsic
validity of the provisions of the will. Under the laws of Texas, there are no forced heirs or legitimes. Accordingly, since the
intrinsic validity of the provision of the will and the amount of successional rights are to be determined under Texas law, the
Philippine law on legitimes cannot be applied to the testacy of the decedent.

HSBC vs Sherman G.R. No. 72494

Facts: A Singaporean Company obtained a loan from HSBC. The directors of the company executed a Joint and Several
Guarantee in favor of HSBC. The company defaulted. Hence, HSBC filed a suit for collection against them before the RTC of
Quezon City. Sherman (company) filed a Motion to Dismiss on the ground of lack of jurisdiction over the complaint and persons
of the defendants. The guarantee provides: “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.”

Issue: Whether or not Philippine courts have jurisdiction over the suit

Ruling: YES. The court construed that the agreement is one of venue and not of jurisdiction.. A stipulation as to venue does not
preclude the filing of suits in the residence of plaintiff or defendant under Sec 2 (b), Rule 4 of the Rules of Court, in the absence
of qualifying or restrictive words in the agreement which indicate that the place named is the only venue agreed upon by
the parties. The parties did not thereby stipulate that only the courts of Singapore, to the exclusion of all the rest, have
jurisdiction. Neither did the clause in question operate to divest Philippine courts of jurisdiction. 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. Jurisdiction cannot be fixed nor changed by the parties; but venue can be changed or transferred by the parties to
another place.

Aznar vs Garcia G.R. No. L-16749

Facts: Edward Christensen is a citizen of the State of California and domiciled in the Philippines. He executed in his will
acknowledging his natural daughter Maria Lucy Christensen as sole heir but left a legacy of some money in favor of Helen
Christensen Garcia who is declared by the Supreme Court in its decision as acknowledged natural daughter of Edward C.
Counsel of Helen asserts that her claim must be increased in view of the successional rights of illegitimate children under Phil.
law. Counsel of Maria insists that Art. 16 (2) provides that the NATIONAL LAW OF THE PERSON applies in intestate and
testamentary successions and since Edward C. is a citizen of CA, its law should be applied. Lower court ruled that CA law should
be applied thus this petition for review.

Issue: What law should be applicable – Philippine or California Law?

Ruling: Philippine law governs. The renvoi doctrine is usually pertinent where the decedent is a national of one country, and a
domicile of another. Article 16 of the Civil Code provides that the intrinsic validity of testamentary dispositions are governed by
the national law of the decedent, in this case, California law. The provision in the laws of California giving a testator absolute
freedom in disposing of his estate is the internal law which applies only to persons domiciled within the said estate. On the other
hand, the provision in the laws of California stating that personal property is governed by the laws of the domicile of its owner is
the conflict of laws rule that applies to persons not domicile in the said state. Accordingly, the laws of the Philippines, in which
the testator is domiciled governs the succession and the regime of legitimes must be respected. The court must apply its own rule
in the Philippines as directed in the conflicts of law rule in CA, otherwise the case/issue will not be resolved if the issue is
referred back and forth between 2 states.