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All ▸ Bar 2024 ▸ CIVIL LAW ▸ I. EFFECT AND APPLICATION OF LAWS ▸ M. Conflict of Laws (Civil Code, arts. 15-18) ▸ 2. Choice of Law, Doctrine of Renvoi, Doctrine of Processual Presumption ▸ h. Lex Loci Solutionis

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Choice of Law and Doctrine of Renvoi: Lex Loci Solutionis

Anna, a Filipino citizen, owns a property in the Philippines. She executed a last will and testament specifically providing that Philippine law shall govern the disposition of her property upon her death. However, upon her demise, it was discovered that Anna also owned properties in other countries.

Discuss the applicability of the doctrine of renvoi in determining the governing law for the disposition of Anna's properties located outside of the Philippines. Explain how this doctrine interacts with the principle of lex loci solutionis.

References:

Article 16 of the Civil Code of the Philippines

Agpalo, R. (2003). Comments on Philippine Conflict of Laws. Manila: Rex Book Store.



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Bar Review Question: Alright, here's the question: Choice of Law and Doctrine of Renvoi: Lex Loci Solutionis Anna, a F