Question

Chris, a Filipino national, owns a property in the Philippines. He dies intestate, leaving behind two heirs: Anna, a Filipino citizen residing in the Philippines, and Ben, a naturalized US citizen residing in the United States. According to the Philippine law on succession, the inheritance would be governed by the principle of lex nationalii, which means that the national law of the decedent will determine the devolution of the estate. However, in cases involving conflict of laws, the doctrine of renvoi may come into play.

In this scenario, assuming that the doctrine of renvoi is recognized in the Philippine legal system:

1. Discuss the concept of lex nationalii and how it relates to the choice of law in succession cases.
2. Explain the doctrine of renvoi and its significance in determining the applicable law in this specific scenario.
3. Would the Philippine courts apply the doctrine of renvoi in this case? Justify your answer.