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 ▸ h. Lex Loci Solutionis

Question

Choice of Law: Lex Loci Solutionis

Scenario:

In a dispute between two parties involving a breach of contract, the contract contains a choice of law provision stating that the laws of the Philippines will govern the agreement. However, the performance of the contract took place in Japan. The parties are now in disagreement as to which jurisdiction's law should apply in resolving their dispute.

Discuss the principle of Lex Loci Solutionis and its significance in determining the applicable law in this case.

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