Question

John, a Filipino citizen, lived and worked in the United States for several years. During his time there, he accumulated significant assets, including a real estate property in California. He recently passed away, leaving behind a last will and testament that was executed and notarized in California, designating his daughter, Maria, as the sole beneficiary of his estate.

In the Philippines, the applicable law regarding the validity of wills is the Civil Code of the Philippines. However, the Philippines adopts the doctrine of renvoi, which means that it may refer the case back to the foreign law in question.

In this scenario, Maria seeks to have her father's will recognized and enforced in the Philippines. She argues that the California law, which allows for a holographic will to be valid even without the presence of witnesses, should be applied in determining the validity of her father's will. On the other hand, John's other legal heirs argue that the Philippine law on wills should be applied, as John was a Filipino citizen at the time of his death.

Discuss the issues surrounding the choice of law and the application of the doctrine of renvoi in this case. Consider the implications of the doctrine of processual presumption in determining the validity and enforceability of John's will under the lex domicilii.