The national law of a foreign decedent determines the intrinsic validity of their will, the order of succession, the amount of successional rights, and the capacity to succeed, even if the properties are located in the Philippines; Philippine laws on legitimes and public policy do not apply to the succession of foreign nationals.

Amos G. Bellis, a citizen of Texas, U.S.A., had legitimate children from two marriages and three illegitimate children. He executed a will in the Philippines, where some of his assets were located, providing specific legacies for his first wife and his three illegitimate children, with the remainder of his estate going to his seven legitimate children. At the time of his death, he was a resident of Texas. The will did not conform to the Philippine system of legitimes, which grants compulsory shares to illegitimate children.

• Amos G. Bellis was a citizen of the State of Texas, U.S.A., and a resident of San Antonio, Texas at the time of his death on July 8, 1958.
• He executed a will in the Philippines on August 5, 1952, which was admitted to probate in the Court of First Instance of Manila.
• The will directed that his estate be divided as follows: $240,000.00 to his first wife, P120,000.00 (or P40,000.00 each) to his three illegitimate children (Maria Cristina, Miriam Palma, and Amos Jr.), and the remainder to his seven surviving legitimate children from his first and second marriages.
• The executor, People's Bank and Trust Company, submitted a project of partition in accordance with the will's provisions after paying the specified legacies.
• Maria Cristina Bellis and Miriam Palma Bellis, two of the illegitimate children, opposed the project of partition, arguing that they were deprived of their legitimes as compulsory heirs under Philippine law.

• The appellants (illegitimate children) argued that they were deprived of their legitimes, which are guaranteed to compulsory heirs under Philippine law.
• They contended that Article 17, paragraph 3 of the Civil Code, which states that prohibitive laws concerning public order and good customs shall not be rendered ineffective by foreign laws, should be treated as an exception to the general rule in Article 16, paragraph 2.
• They also claimed that by executing a separate will for his Philippine estate, the decedent intended for Philippine law to govern the disposition of those assets.

• The appellees (executor and legitimate children) maintained that the successional rights and intrinsic validity of the will should be governed by the national law of the decedent, Amos G. Bellis, which is Texas law.
• They pointed out that the parties admit that Texas law does not provide for legitimes or forced heirs.
• Therefore, the will, which did not provide for legitimes, was intrinsically valid, and the project of partition based on it was correct and should be approved.

• Procedural Issues:
  • N/A
• Substantive Issues:
  • Whether the intrinsic validity of the testamentary provisions of the deceased, specifically the allocation of his estate, should be governed by his national law (Texas law) or by Philippine law.

• Procedural:
  • N/A
• Substantive:
  • The Supreme Court affirmed the order of the probate court, ruling that the national law of the decedent, Texas law, must govern his succession. The Court held that Article 16, paragraph 2 of the Civil Code is a specific provision that explicitly mandates that the amount of successional rights and the intrinsic validity of a will are regulated by the decedent's national law, regardless of the nature or location of the property. This specific provision prevails over the general provision of Article 17 concerning public policy. The Court also dismissed the applicability of the doctrine of renvoi, as the decedent was both a national and a domiciliary of Texas, leaving no room for a "reference back" to Philippine law. Finally, the decedent's intent is irrelevant because the applicable law on succession is mandatorily prescribed by the Civil Code and cannot be changed by the testator's will.

• Lex Nationalii (Nationality Principle) — This principle, embodied in Article 16 of the Civil Code, dictates that successional matters, including the order of succession, amount of successional rights, and intrinsic validity of a will, are governed by the national law of the person whose succession is under consideration. The Court applied this doctrine directly, stating that since Amos Bellis was a citizen of Texas, Texas law governs his succession, not Philippine law.
• Doctrine of Renvoi — This doctrine refers to a situation where a court, following its conflict of laws rule, refers a case to a foreign law, which in turn refers the matter back to the law of the forum. The Court found this doctrine inapplicable because the decedent was both a national and a domiciliary of Texas, so there was no conflict between his national law and domiciliary law that could result in a renvoi to the Philippines.
• Statutory Construction Principle: Specific provisions prevail over general ones — The Court applied this principle to resolve the apparent conflict between Article 16 and Article 17 of the Civil Code. It ruled that Article 16, which specifically governs successional rights, is the controlling provision and prevails over the general language of Article 17 regarding public policy.

• "It is therefore evident that whatever public policy or good customs may be involved in our system of legitimes, Congress has not intended to extend the same to the succession of foreign nationals. For it has specifically chosen to leave, inter alia, the amount of successional rights, to the decedent's national law. Specific provisions must prevail over general ones."

• Aznar v. Christensen Garcia — This case was mentioned in the context of the doctrine of renvoi. The Court distinguished it from the present case because in Aznar, the decedent was a US citizen domiciled in the Philippines, creating a conflict that triggered renvoi. In Bellis, the decedent was both a citizen and a domiciliary of Texas, making renvoi inapplicable.
• Miciano v. Brimo — This case was cited to support the principle that a testator cannot validly provide in his will that his succession shall be governed by a law other than his national law. Any such provision is considered illegal and void because the application of the national law as per Article 16 of the Civil Code is mandatory.

• Civil Code, Article 16 — This was the central legal basis for the Court's decision. Its second paragraph explicitly provides that intestate and testamentary successions shall be regulated by the national law of the person whose succession is under consideration, covering the order of succession, amount of rights, and intrinsic validity of the will.
• Civil Code, Article 17 — This article, raised by the appellants, states that prohibitive laws concerning persons, their acts, property, public order, public policy, and good customs shall not be rendered ineffective by foreign laws. The Court ruled that this general provision does not override the specific provision of Article 16 in matters of succession.
• Civil Code, Article 1039 — This article, which states that the capacity to succeed is governed by the law of the nation of the decedent, was cited by the Court as further proof of the legislative intent to apply the nationality principle in succession.