Practice question
A contract is executed in Country A, specifies performance of its central service obligation in Country B, and includes a governing-law clause choosing Country C. A party labels all three places lex loci solutionis and says no further analysis is possible. Which is the correct response?
- Distinguish making, performance and chosen law; Country B supplies the stated performance connector, while governing law requires the applicable analysis.
- All three places necessarily mean performance.
- Country A andCountry C cease to exist as relevant facts.
- A governing-law clause can never matter.
- The court must decide solely by alphabetical order.
Legal references
- Saudia v. Rebesencio, G.R.198587, January14 2015, main decision, choice-of-law discussion; https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/60343
- Civil Code Article17; https://lawphil.net/statutes/repacts/ra1949/ra_386_1949.html
Answer this question in flashcards to review your response and continue practicing.