Flashcards Studio

A Filipino citizen, Mateo Santos, dies in Singapore, leaving two immovable properties: Lot 11, a Manila parcel registered under Torrens title, and Lot 12, a land parcel in Bangkok, Thailand (Thai title). In his will he states: "All immovable properties I own, wherever located, shall be disposed of according to the law of the place where the immovable is situated." He designates his Filipino son, Leo, as heir to Lot 11 and his Thai son-in-law, Anan, as heir to Lot 12. (a) Identify the controlling doctrine at issue and explain whether the Philippines recognizes renvoi in the context of real property. (b) Determine which law governs the disposition of Lot 11 and Lot 12 under lex situs and any possible renvoi. (c) Assess whether Leo’s claim to Lot 11 and Anan’s claim to Lot 12 are valid under Philippine conflict-of-laws rules and the constitutional prohibitions on alien ownership of land.