Question

You are a lawyer representing a party involved in a dispute over a property located in the Philippines. The dispute arose due to conflicting claims between the original owner, John, and a subsequent buyer, Sarah.

John, a Filipino citizen, purchased the property from the original owner, David, who is also a Filipino citizen. At the time of the sale, both parties executed a Deed of Sale in accordance with Philippine laws. However, David failed to transfer the title of the property to John before his death.

A few months after David's death, Sarah, a British citizen, discovered the property and expressed interest in purchasing it. She proceeded to negotiate and enter into a purchase agreement with David's heirs, who are also British citizens. The transaction took place in the Philippines and was executed in accordance with British law.

In the course of the dispute between John and Sarah, the issue of which country's law should govern the dispute arises, particularly with regards to the principle of lex rei sitae. Analyze the legal framework, including the doctrine of renvoi and the doctrine of processual presumption, and discuss which jurisdiction's law should apply in determining the rightful owner of the property.

1. Discuss the concept of lex rei sitae and its significance in resolving conflicts of law related to immovable property.
2. Explain the doctrine of renvoi and its application in determining the applicable law in the present scenario.
3. Evaluate the doctrine of processual presumption and its impact on the determination of the rightful owner of the property.