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 ▸ c. Lex Contractus

Question

Choice of Law and Lex Contractus

Scenario: John, a resident of the Philippines, enters into a contract with Maria, a resident of the United States, for the purchase of a rare collectible item. The contract does not specify the applicable law.

Based on the facts given, discuss the following:

Which law governs the contractual relationship between John and Maria? Explain your answer.

If the doctrine of renvoi is invoked, what would be the effect on the choice of law? Provide an explanation.

How does the doctrine of processual presumption come into play in determining the applicable law in this scenario?

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