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Question
Fatima Villanueva, a Filipino citizen, domiciled in Milan, Italy, dies in Milan leaving a will executed in Italy. The will disposes of (i) a savings deposit in a Philippine bank (movable) and (ii) a titled parcel of land in Antique, Philippines (immovable). The will contains no Philippine formality relating to land transfers. For Fatima’s estate, (a) Identify the central doctrine of Lex domicilii and state the general rule for the disposition of movables versus immovables in cross-border situations. (b) For the estate, which law governs (i) the disposition of movables (the Philippine bank deposit) and (ii) the disposition of the Philippine land? (c) If the will attempts to devise the Philippine land to a Filipino citizen domiciled in Singapore, discuss the likely outcome under conflict-of-laws rules and Philippine land ownership laws.