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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 ▸ f. Lex Fori

Question

Choice of Law: Lex Fori

Angelica, a Filipino citizen who resides in the Philippines, entered into a contract with Bruno, a French citizen who resides in France. The contract includes a clause stating that any disputes arising from the contract shall be governed by the laws of France. A dispute arises between Angelica and Bruno, and Angelica files a lawsuit in a Philippine court.

Discuss the following:

  1. What is the principle of lex fori in relation to choice of law?
  2. What would be the legal effect of the choice of law clause in the contract?
  3. Considering the lex fori principle, what law would the Philippine court apply in deciding the dispute?


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Bar Review Question: Choice of Law: Lex Fori Angelica, a Filipino citizen who resides in the Philippines, entered into