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Philippine Commercial and Industrial Bank vs. Escolin G.R. No. L-27860 March 29, 1974 Facts

A married woman who was a citizen of Texas but lived in the Philippines died. There was a question over the validity of provisions in her will that benefited her husband. Specifically, there was debate over whether Texas law at the time of her death should apply or if the concept of renvoi could apply Texas law from another time. The Supreme Court ruled that Texas law at the precise moment of the woman's death must be determined based on evidence presented in probate court, not Texas law from any other time period.

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48 views1 page

Philippine Commercial and Industrial Bank vs. Escolin G.R. No. L-27860 March 29, 1974 Facts

A married woman who was a citizen of Texas but lived in the Philippines died. There was a question over the validity of provisions in her will that benefited her husband. Specifically, there was debate over whether Texas law at the time of her death should apply or if the concept of renvoi could apply Texas law from another time. The Supreme Court ruled that Texas law at the precise moment of the woman's death must be determined based on evidence presented in probate court, not Texas law from any other time period.

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ARTICLE 3

PHILIPPINE COMMERCIAL AND INDUSTRIAL BANK vs. ESCOLIN


G.R. No. L-27860 March 29, 1974

Facts:
Linnie Jane Hodges, a married woman and a citizen of Texas, USA, was a domiciliary of the
Philippines at the moment of her death. With respect to the validity of certain testamentary provisions
she had made in favor of her husband, a question arose as to what exactly were the laws of Texas on
the matter at the precise moment of her death (for while one group contended that the Texan law
should result to renvoi, the other group contended that no renvoi was possible).

Issue:
Whether or not Texas Law should apply.

Ruling:
The Supreme Court held that for what the Texas law is on the matter, is a question of fact to
be resolved by the evidence that would be presented in the probate court. Texas law at the time of her
death (and not said law at any other time).

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