Question

In a commercial contract entered into between a Philippine company and a foreign company, a dispute arises regarding the applicable law to govern the contract. The Philippine company argues that Philippine law should apply as it is the lex contractus, while the foreign company insists that the law of its home country should govern the contract. Evaluate the following scenarios and determine the correct application of the choice of law principles:

1. The contract was executed in the Philippines, and the performance of the contractual obligations will also be carried out in the Philippines.
2. The contract was executed in the Philippines, but the performance of the contractual obligations will be carried out in the foreign company's home country.
3. The contract was executed in the foreign company's home country, but the performance of the contractual obligations will be carried out in the Philippines.
4. The contract was executed in the foreign company's home country, and the performance of the contractual obligations will also be carried out in the foreign company's home country.