Question

Choice of Law and Doctrine of Renvoi: Lex Fori

John, a resident of the Philippines, entered into a contract with Emily, a resident of Singapore, for the purchase of a property located in Malaysia. The contract stipulates that any disputes arising from the contract shall be governed by Philippine law. A dispute arises regarding the interpretation of certain contractual provisions, and both parties seek legal recourse.

Based on the scenario provided, determine the following:

1. What is the significance of the choice of law clause in the contract? (2 points)
2. Under the doctrine of renvoi, what will the court do if it finds that the applicable law leads back to the law of another jurisdiction? (3 points)
3. Explain the doctrine of processual presumption and its relevance in this scenario. (5 points)
4. Considering the principle of lex fori, which law will likely govern the resolution of the dispute? What factors should the court consider in making this determination? (5 points)