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AllBar 2024CIVIL LAWI. EFFECT AND APPLICATION OF LAWSM. Conflict of Laws (Civil Code, arts. 15-18)2. Choice of Law, Doctrine of Renvoi, Doctrine of Processual Presumptionc. Lex Contractus

Question

Choice of Law in Contract Dispute: Lex Contractus

In a contract dispute between two parties, Anna, a resident of the Philippines, and Ben, a resident of Singapore, both entered into a written agreement for the sale of goods. The contract did not include a choice of law clause, leaving the determination of the applicable law to be determined by the court.

Anna claims that Philippine law should govern the contract since she is a resident of the Philippines. On the other hand, Ben argues that Singapore law should apply, as the contract was entered into while he was physically present in Singapore.

Given the scenario above, determine the applicable law to the contract dispute between Anna and Ben, based on the doctrine of Lex Contractus and explain your answer.




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