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:

Juan and Maria, both Filipino citizens, got married in the Philippines. After several years of marriage, they encountered irreconcilable differences and decided to separate. Juan is now residing in the United States, while Maria is residing in Singapore. They have agreed to file for divorce in their respective countries.

In this scenario, which country's law will be applied to determine the validity and effects of the divorce?

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