Practice question
An RTC denies a motion challenging only subject-matter jurisdiction. Its order discusses a place-of-performance theory. A litigant treats Hasegawa as a definitive Supreme Court merits ruling selecting substantive law for every foreign contract. Which is correct?
- Hasegawa explained that its issue was jurisdiction and that merits choice-of-law rules were not yet called for
- Hasegawa made every foreign contract subject to one universal law
- A lower court’s reason automatically becomes a universal holding
- Jurisdiction and substantive law are identical
- No contract may contain foreign elements
Legal references
- Hasegawa v. Kitamura, G.R. No. 149177, November 23, 2007, main decision: https://lawphil.net/judjuris/juri2007/nov2007/gr_149177_2007.html
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