Practice question
An overseas employment contract is executed in the Philippines and specifies no foreign governing law. Applying the point addressed in IPAMS, does foreign performance alone necessarily establish that foreign labor law governs?
- Yes, because Philippine execution is always irrelevant.
- Yes, because every foreign employer's law automatically governs.
- Yes, because choice of law needs no analysis.
- No. IPAMS applies Philippine law in the stated no-choice Philippine-execution setting.
- No, because foreign law can never be considered in any contract.
Legal references
- IPAMS v. De Vera, G.R.205703, March7 2016, main decision, contractual choice of law and lex loci contractus; https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/61749
- Civil Code Articles17 and1306; https://lawphil.net/statutes/repacts/ra1949/ra_386_1949.html
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