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 ▸ a. Lex Nationalii

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Choice of Law and Doctrine of Renvoi in the Philippines

Anton and Juan, both Filipino citizens, entered into a contract for the sale of a property located in Canada. The contract stipulated that the laws of the Philippines will govern any disputes arising from the agreement. A dispute arises between the parties regarding the interpretation of certain provisions of the contract.

In this scenario, discuss the following:

Which law would the Philippine courts apply to resolve the dispute?
What factors would the courts consider in determining the choice of law?
Would the Doctrine of Renvoi be applicable in this case?

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