Question

Alex and Ben are residents of different countries -- Alex is a resident of the Philippines and Ben is a resident of the United States. They entered into a contract for the sale of goods, and a dispute regarding the contract has arisen. The contract does not contain a choice of law clause.

Based on the facts given, identify and discuss the relevant principles and rules regarding the choice of law and the application of the doctrine of renvoi in determining the applicable law (lex contractus) to resolve the dispute between Alex and Ben.

1. Explain the choice of law principles applicable in this situation and the factors that may be considered in determining the governing law for the contract.
2. Discuss the doctrine of renvoi and how it may impact the determination of the applicable law in this case.
3. Apply the relevant choice of law principles and discuss the possible outcomes if the dispute is resolved under Philippine law and if it is resolved under U.S. law.
4. Explain any limitations or exceptions to the doctrine of renvoi and discuss their potential application in this situation.