Question

1. Jose, a Philippine resident, entered into a contract with Maria, a resident of Singapore, for the sale of goods. The contract did not specify the applicable law. The goods were supposed to be delivered in the Philippines. However, a dispute arose regarding the delivery of the goods, and Jose filed a lawsuit in the Philippine court seeking specific performance of the contract.

a. What law will the Philippine court apply in resolving the dispute regarding the delivery of the goods?

2. Rebecca, a Filipino citizen, filed for divorce against her husband, David, who is a British citizen. The couple was married in the Philippines, but they have been living in the United Kingdom for the past five years. Rebecca wants the divorce to be recognized in the Philippines so that she can remarry. David, however, opposes the divorce and argues that Philippine courts do not have jurisdiction over their divorce.

b. Based on the principle of lex loci solutionis, will the Philippine court recognize Rebecca and David's divorce decree obtained in the United Kingdom?