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 ▸ b. Lex Rei Sitae

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Choice of Law and Doctrine of Renvoi: Lex Rei Sitae

Anabelle and Benjie, both Filipino citizens, got married in the United States. They subsequently acquired a property in California, USA. A few years later, they decided to divorce. Anabelle, who has since relocated to the Philippines, filed for divorce in a Philippine court. The issue at hand is the validity of the divorce and its effect on the ownership of the property in California.

Based on the lex rei sitae principle, which jurisdiction's law should govern the issue of the validity of the divorce and the ownership of the property? Discuss the application of the doctrine of renvoi in this case, if applicable.

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