Sucesión internacional: algunos problemas relativos a la aplicación de la norma de conflicto a través de la reciente práctica jurisdiccional española

This essay analyzes the problerns of application of the conflict of laws rule through the spanish practice on courts in the subject of intemational successions. Problems of renvoi, application of foreing laws with different local civil law systerns, adaptation in the subject of succession rights of the survivor member of the marriage, the incidental question, and the application of a foreing law repugnant to spanish public policy are analyzed. In these whole court activitity, the common point is the lack of security of the judge. On one hand, think about the spanish legislator labour: sometimes, its activity gives to judge some statutes that can not salve most of the problems created by the application of the conflict of laws rule; other times, it does not give any norm of support. On the other, see the practice on courts. A f ew resolutions show advances in sorne aspects, but most show the non-attention of the norm of support by the judge, its authomatic application, or its applicability in case without paying attention to important items as authonomy of will or the true principies that inspire the Spanish conflict of laws rule in intemational successions, the art. 9.8 Spanish Civil Code.