LLORENTE vs CA FACTS: Petitioner was married to a US Navy enlisted serviceman Lorenzo Llorente, in Nabua, Camarines Sur, on February 22,

1937. Before the outbreak of war, Lorenzo departed for the US and Paula stayed in the conjugal home in Nabua. Lorenzo became an American citizen on November 30, 1943. Upon the liberation of the Philippines (1945), Lorenzo was granted by the US Navy to visit his wife in the Philippines and found out that Paula was living in with Lorenzos brother Ceferino. In December 1945, Paula gave birth to Crisologo with the birth certificate saying that the child was illegitimate, and the fathers name was left blank. On February 2, 1946, Paula and Lorenzo had a written agreement, dissolving their marital union, suspending his support upon her, and waiving his authority to file a case of adultery against her. Lorenzo returned to the US and filed for a divorce in 1951 which was granted in 1952. On January 16, 1958, Lorenzo married Alicia Fortuno, in the Philippines; afterwhich, they bore three children: Raul, Luz, and Beverly. In 1981, Lorenzo executed a will, bequeathing all his property to Alicia and three children. Before the proceeding could be terminated, Lorenzo died in 1985. On Sept. 4, 1985, Paula filed with the RTC of Iriga a petition for letters of administration over Lorenzos estate, contending that she was Lorenzos surviving spouse. In 1987, the RTC granted her petition, stating that Lorenzos divorce decree was void and inapplicable in the Philippines and therefore his marriage to Alicia was void. The RTC entitled Paula to one-half of their conjugal properties, and one-third of the estate the two-thirds would be divided equally among the illegitimate children. Paula was appointed as legal administratix of the estate. ISSUE: Whether or not Paula Llorente was entitled to inherit from the estate of Lorenzo Llorente. HELD: Since Lorenzo was an American citizen, issues arising from the case are governed by foreign law. The CA and RTC called to the fore the renvoi doctrine, where the case was referred back to the law of the decedents domicile, in this case, the Philippine law. Most US laws follow the domiciliary theory. Thus, the Philippine law applies when determinging the validity of Lorenzos will.