Practice question
A contract is signed in Country A but requires delivery of the relevant goods in Country B. Explain which fact identifies the performance connector and why that answer alone does not decide all questions of formal validity and substantive governing law.
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
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