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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 ▸ d. Lex Loci Celebrationis

Question

Choice of Law and Lex Loci Celebrationis

Scenario:

Marie and John, both Filipino citizens, got married in the United States. They recently moved back to the Philippines and are experiencing marital issues. Marie wants to file for divorce, while John wants to seek an annulment. They are confused about which law will govern their case.

Question:

Discuss the application of the doctrine of Lex Loci Celebrationis in determining the applicable law for Marie and John's case. What factors should be considered in determining the jurisdiction with regards to the validity of their marriage?



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Bar Review Question: Choice of Law and Lex Loci Celebrationis Scenario: Marie and John, both Filipino citizens, got ma