Question

You are a legal advisor handling a complex cross-border divorce case involving a Filipino couple who got married in the Philippines and later obtained American citizenship. The couple has now decided to file for divorce, and the main issues to be resolved include the division of properties, child custody, and spousal support. The husband asserts that American laws should govern the divorce proceedings, while the wife insists on applying Philippine laws.

Based on the doctrine of lex domicilii, which law should be applied in determining the divorce proceedings? Explain your answer and justify your choice, focusing on the legal principles and provisions that govern the choice of law in this situation.