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AllBar 2024CIVIL LAWI. EFFECT AND APPLICATION OF LAWSM. Conflict of Laws (Civil Code, arts. 15-18)2. Choice of Law, Doctrine of Renvoi, Doctrine of Processual Presumptionh. Lex Loci Solutionis

Question

Choice of Law: Lex Loci Solutionis

In a maritime accident case involving a collision of two vessels, an international shipping company based in the Philippines filed a lawsuit against a foreign shipping company based in Japan for damages. The collision occurred in international waters. The issue at hand is which law should govern the determination of liability and damages in this case.

Discuss the concept of Lex Loci Solutionis in the context of choice of law. Analyze whether the Lex Loci Solutionis principle should be applied in this maritime accident case. Provide reasons for your answer, taking into consideration the relevant laws and jurisprudence.




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Bar Review Question: Choice of Law: Lex Loci Solutionis