Question

Choice of Law and Doctrine of Renvoi in a Contract Dispute

Carlos, a resident of the Philippines, entered into a contract with Maria, a resident of the United States, for the sale of a valuable antique. The contract did not contain a choice of law clause. The contract was executed in the Philippines, but the antique was physically transferred to Maria in the United States. A dispute arises regarding the validity of the contract, and both parties seek legal remedies in their respective jurisdictions.

Based on the facts presented, discuss the following:

1. How will the court in the Philippines determine the applicable law to resolve the contract dispute?
2. If the court in the Philippines applies the Doctrine of Renvoi, what factors will it consider in determining which foreign law to apply?
3. What is the legal consequence if the court in the Philippines applies the Doctrine of Processual Presumption in resolving the contract dispute?