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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 Presumptionh. Lex Loci Solutionis

Question

Choice of Law in International Contracts - Lex Loci Solutionis

Scenario:

Alpha Corporation, a Philippine-based company, entered into a contract with Beta Corporation, a Singaporean company, for the sale and delivery of goods. The contract did not specify the governing law. A dispute arises between the parties regarding the performance of the contract.

Question:

Under the principles of choice of law, in the absence of a specific governing law provision in the contract, what law governs the performance and validity of the contract between Alpha Corporation and Beta Corporation? Discuss and explain.




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Bar Review Question: Choice of Law in International Contracts - Lex Loci Solutionis Scenario: Alpha Corporation, a Phi