Questão jurídica principal
Whether the pre-1987 matrimonial regime was governed by the law of the first matrimonial domicile or by the law of the last foreign domicile before Switzerland
Decisão extraída
For spouses who were domiciled abroad before moving to Switzerland, the applicable law for the internal matrimonial regime is the law of the last foreign domicile, not the law of the first matrimonial domicile.
Fundamentação extraída
The court applied the former LRDC and preferred the analogue of Art. 31 al. 3 LRDC over Art. 19 LRDC; the latter is tailored to intercantonal situations and does not extend by analogy to foreign spouses.