Question

Juan, a Filipino businessman, entered into a contract with Maria, a Spanish national, for the sale of goods. The contract contained a choice of law clause stating that any dispute arising from the contract shall be governed by the laws of the Philippines. However, the goods were delivered in Spain. A dispute has now arisen between Juan and Maria regarding the performance of the contract. They seek your advice on which law should apply in resolving their dispute.

Based on the given scenario, determine the applicable law or theory in resolving the dispute between Juan and Maria.

1. Explain the principle of lex contractus and its relevance in determining the applicable law in contracts.
2. Discuss the doctrine of renvoi and its potential application in the given scenario.
3. Examine the doctrine of processual presumption and its impact on the choice of law.