Practice question
A foreign citizen dies owning Philippine assets. The applicable national succession law is properly proved and contains no compulsory share of the kind an heir claims under Philippine law. No referral back or other applicable exception is established. The heir relies solely on the Philippine location of assets to demand Philippine legitimes. Following Bellis, which analysis is strongest?
- All foreign estates automatically use Philippine legitimes
- The heir’s preferred law always controls
- Article 16’s national-law succession rule cannot be displaced merely by the assets’ Philippine location
- The executor may choose any law after death
- Domicile and nationality always mean the same thing
Legal references
- Bellis v. Bellis, G.R. L-23678, June 6, 1967: https://lawphil.net/judjuris/juri1967/jun1967/gr_l-23678_1967.html
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