Renvoi takes place when the conflicts rule of the forum makes a reference to a foreign law, but the foreign law is found to contain a conflict rule that returns or refers the matter back to the law of the forum (Remission).
The recognition of the renvoi theory implies that the rules of the conflict of laws are to be understood as incorporating not only the ordinary or internal law of the foreign state or country, but its rules of the conflict of laws as well. Consequently, the court of the domicile cannot and should not refer the case back to California; such action would leave the issue incapable of determination because the case will then be like a football, tossed back and forth between the two states, between the country in which the decedent was a citizen and the country of his domicile. The Philippine court must apply its own law as directed in the conflict of laws rule of the state of the decedent. (Aznar vs. Garcia, G.R. No. L-16749, January 31, 1963)
