A, While Travelling in Cananda Executed a Will Before Philippine

A, while travelling in Cananda executed a will before Philippine Consul B with only two (2) witnesses. Under Canadian Law, two (2) witnesses would suffice. When he arrived in the Philippines he filed a petition for probate. How do you think the court will decide?

A) It will admit the will to probate because of the doctrine of lex loci celebrationis.
B) It will not admit the will to probate unless probated first in Canada.
C) It will deny probate because of failure to comply with the formalities under Philippine law. (Art. 17, NCC)
D) It will admit the will to probate because Canadian laws cannot apply in the Philippines if proven as facts according to the rules of evidence.

Correct Answer:

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