Practice question
Heirs invoke renvoi because Philippine property forms part of a foreign decedent’s estate. They offer no proof of a foreign conflicts rule referring the succession issue to the property’s situs. They demand automatic application of Philippine legitimes. What caution follows from Bellis?
- Philippine property proves every foreign conflicts rule
- Foreign nationality always eliminates the national-law rule
- A reference back cannot simply be invented; the asserted foreign conflicts rule and relevant facts must be established
- Every will concerning local property is void
- The heirs may select any foreign rule after judgment
Legal references
- https://lawphil.net/statutes/repacts/ra1949/ra_386_1949.html — Civil Code, Article 16
- https://lawphil.net/judjuris/juri1963/jan1963/gr_l-16749_1963.html — Aznar v. Garcia, G.R. No. L-16749, January 31, 1963
- https://lawphil.net/judjuris/juri1967/jun1967/gr_l-23678_1967.html — Bellis v. Bellis, G.R. No. L-23678, June 6, 1967
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