Practice question
Two foreigners litigate an ordinary issue concerning ownership of land situated in the Philippines. No succession question or other special conflict rule is involved. Which basic Article 16 connector applies?
- The older litigant’s birthplace
- The Philippine situs of the land
- The notary’s holiday destination
- The parties’ preferred foreign rule automatically
- The payment currency alone
Legal references
- Civil Code Article 16, first paragraph: https://lawphil.net/statutes/repacts/ra1949/ra_386_1949.html
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