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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

You are a lawyer representing a client involved in a contractual dispute with a foreign company. The contract states that any disputes will be resolved in accordance with the laws of the country where the contract was signed. The contract was signed in the Philippines. However, the foreign company argues that another country's laws should apply to resolve the dispute.

Based on the doctrine of Lex Loci Solutionis, discuss whether the Philippine courts would likely apply the laws of the Philippines or the laws of the foreign country in resolving the dispute. Please provide a comprehensive analysis and support your answer with applicable laws and precedents.




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Bar Review Question: Choice of Law: Lex Loci Solutionis You are a lawyer representing a client involved in a contractual