Question

You are a legal advisor for a multinational corporation based in the Philippines. The company entered into a contract with a foreign entity to supply goods. The contract includes a choice-of-law clause that states the laws of the Philippines shall govern the agreement.

A dispute arises between the parties concerning the interpretation of certain contractual provisions. The foreign entity argues that the choice-of-law clause should be disregarded, and the laws of their home country should apply.

Discuss the applicable principles of choice of law with respect to the doctrine of Lex Contractus. Explain whether the foreign entity's argument is valid, and support your reasoning with relevant jurisprudence.