All ▸ Bar 2024 ▸ CIVIL LAW ▸ I. EFFECT AND APPLICATION OF LAWS ▸ M. Conflict of Laws (Civil Code, arts. 15-18) ▸ 2. Choice of Law, Doctrine of Renvoi, Doctrine of Processual Presumption ▸ e. Lex Domicilii

Question

Choice of Law: Lex Domicilii

Scenario:

John, a Filipino citizen, owns a property in the Philippines. He acquired the property through inheritance from his deceased father, who was a permanent resident of the United States. John currently resides in California, USA, and has been considering selling the property in the Philippines. However, he is unsure which country's laws should govern his sale transaction.

Question:

Based on the principle of lex domicilii, which country's laws should govern John's sale transaction? Explain your answer.

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