Practice question
A Philippine tribunal has jurisdiction over a transnational contract dispute. A party says this alone conclusively resolves every substantive choice-of-law question, including any performance-place issue. What does Rebesencio explain?
- Jurisdiction always requires forum substantive law on every issue.
- Every foreign element automatically removes jurisdiction.
- The place of performance is always the judge's office.
- Only citizenship determines jurisdiction and governing law.
- Jurisdiction and choice of law are distinct inquiries.
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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