Question

Choice of Law, Doctrine of Renvoi, Doctrine of Processual Presumption: Lex Loci Solutionis

In a contractual dispute involving parties from different jurisdictions, the issue of the applicable law often arises. The principle of Lex Loci Solutionis, or the law of the place where the contract is performed, is commonly used as a choice of law rule in such cases. Consider the following scenario:

Alfredo, a resident of the Philippines, entered into a contract with Maria, a resident of Spain, for the purchase and delivery of a vintage car. The contract was executed in the Philippines, and the car was to be delivered to Alfredo's residence in Manila. Due to a breach of contract, Maria failed to deliver the car as agreed.

Discuss the application of Lex Loci Solutionis in determining the applicable law and its implications in resolving the contractual dispute between Alfredo and Maria.