Question

A and B, both residents of the Philippines, entered into a contract for the sale of a property located in the United States. The contract stipulates that the laws of the Philippines shall govern the agreement.

A dispute arises between A and B regarding the interpretation of certain terms in the contract. They approach you as their legal advisor and seek guidance on the applicable law to resolve their dispute.

Given the scenario, discuss the following:

1. What is the concept of "Lex Contractus" and its significance in this case?
2. Under Philippine law, how is the choice of law determined in contracts with international elements?
3. Explain the doctrine of Renvoi and its application to the situation.
4. Considering the facts of the case, which jurisdiction's laws should govern the contract, the Philippines or the United States? Provide the legal basis for your answer.