Amos Bellis, born in Texas, was a citizen of the State of Texas and of the United States.

He had 5 legitimate children

with his wife, Mary Mallen, whom he had divorced, 3 legitimate children with his 2nd wife, Violet Kennedy and
finally, 3 illegitimate children.

Prior to his death, Amos Bellis executed a will in the Philippines in which his distributable estate should be divided
in trust in the following order and manner:

a. $240,000 to his 1st wife Mary Mallen;

b. P120,000 to his 3 illegitimate children at P40,000 each;
c. The remainder shall go to his surviving children by his 1st and 2nd wives, in equal shares.

Subsequently, Amos Bellis died a resident of San Antonio, Texas, USA. His will was admitted to probate in the
Philippines. The Peoples Bank and Trust Company, an executor of the will, paid the entire bequest therein.

Preparatory to closing its administration, the executor submitted and filed its Executors Final Account, Report of
Administration and Project of Partition where it reported, inter alia, the satisfaction of the legacy of Mary Mallen
by the shares of stock amounting to $240,000 delivered to her, and the legacies of the 3 illegitimate children in the
amount of P40,000 each or a total of P120,000. In the project partition, the executor divided the residuary estate
into 7 equal portions
for the benefit of the testators 7 legitimate children by his 1st and 2nd marriages.

Among the 3 illegitimate children, Mari Cristina and Miriam Palma Bellis filed their respective opposition to the
project partition on the ground that they were deprived of their legitimates as illegitimate children.

The lower court denied their respective motions for reconsideration.

ISSUE: Whether Texan Law or Philippine Law must apply.

RULING: TEXAN LAW.

It is not disputed that the decedent was both a national of Texas and a domicile thereof at the time of his death. So
that even assuming Texan has a conflict of law rule providing that the same would not result in a reference back
(renvoi) to Philippine Law, but would still refer to Texas Law.

Nonetheless, if Texas has conflict rule adopting the situs theory (lex rei sitae) calling for the application of the law of
the place where the properties are situated, renvoi would arise, since the properties here involved are found in the
Philippines. In the absence, however of proofs as to the conflict of law rule of Texas, it should not be presumed
different from our appellants, position is therefore not rested on the doctrine of renvoi.

The parties admit that the decedent, Amos Bellis, was a citizen of the State of Texas, USA and that under the Laws
of Texas, there are no forced heirs or legitimates. Accordingly, since the intrinsic validity of the provision of the will
and the amount of successional rights has to be determined under Texas Law, the Philippine Law on legitimates
cannot be applied to the testate of Amos Bellis.

*Article 16, par. 2, and Art. 1039 of the Civil Code, render applicable the national law of the decedent, 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; and (d) the capacity to succeed.

Intestate and testamentary successions, both with respect to the order of succession and to the amount of
successional rights and to the intrinsic validity of testamentary provisions, shall be regulated by the national law of
the person whose succession is under consideration, whatever may he the nature of the property and regardless of
the country wherein said property may be found.