A topic from AEG's L5R CCG Rules forum, copied for Oracle of the Void from a copy of the forum saved in October 2015, so pages it didn't save are missing. Players' names are left out; the rules officials are named. Rulings are as they stood on these dates; later rulings, the rulebooks and the Rules Archive may differ.
A player, 3 July 2009
Can the spell Essence of Gaki-do create presence? Its seems to me like it can as, by its very wording it creates personalities at the current battlefield and the rule of presence only requires that an action end in you having presence but I figured I should ask.
Essence of Gaki-do Gold Cost: 8 Battle: Even if this unit is home, bow this Shugenja, and any number of your other target Shugenja at any location: Create a number of 2F/2C/0PH Spirit Personalities at the current battlefield equal to the number of performing Shugenja. After the battle ends, remove these Spirits from the game.
A player, 3 July 2009
Despite the MRP on Essence of Gaki-do in Celestial Edition, the Rule of Presence still forbids you to take the Battle action from this Spell if you control no units at the current battlefield.
"Even if this unit is home" waives the second part of Rule of Location: you are allowed to take this action if this Spell's unit is either at the current battlefield or at home. However it does not waive the Rule of Presence because it does not read "Even if you control no units at the current battlefield" (see below, emphasis mine).
Battles, The Rule of Presence: The phrase “Even if you control no units at the current battlefield” is intended to waive the rule of Presence, but not necessarily Location.
Battles, The Rule of Location: When found on a card in a unit, phrases such as “Even if [ the card itself ] is not at the current battlefield” or "Even if [ the card itself ] is home" waive only the second part of the Rule of Location. They do not necessarily waive the Rule of Presence or the first part of the Rule of Location.