Question

Choice of Law: Lex Fori

In a civil case involving a contract dispute between a Philippine-based company and a foreign-based company, the parties have agreed to have their dispute resolved through arbitration. The arbitration proceedings are scheduled to take place in the Philippines. The contract does not include a choice of law provision. The foreign-based company argues that the laws of its home country should govern the dispute, while the Philippine company insists that Philippine law should apply. The court is tasked with determining the applicable law.

Discuss the significance and application of the Lex Fori doctrine in resolving this contractual dispute. Include in your discussion the relevant principles, considerations, and legal authorities that should be taken into account by the court in determining the applicable law under the Lex Fori doctrine.