Question

Civil

A and B, both Filipino citizens, got married and eventually settled in California, USA, where they were domiciled for thirty years. During their marriage, they acquired real properties both in California and in the Philippines. A died intestate in California, survived by his spouse, B, and by his siblings, C, D, and E. B sought the distribution of A's Philippine properties under California law, which grants the surviving spouse the entire estate of the deceased when there are no surviving children or parents. C, D, and E opposed, arguing that Philippine law should govern the distribution of A's Philippine properties, under which they are entitled to share in the estate as collateral relatives. Whose contention should prevail? (Bar 2026 Syllabus)

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