Question

John, a Filipino entrepreneur, entered into a contract with Maria, a Spanish businesswoman, for the sale of goods. The contract was executed in the Philippines, but the goods were to be delivered in Spain. However, a dispute arose regarding the performance of the contract, leading to a potential legal action.

The issue at hand is which law should govern the contract between John and Maria. Specifically, in relation to the doctrine of Lex Loci Delicti, which refers to the principle that the law of the place where the tort was committed should apply, discuss the following scenarios:

1. Scenario 1: The alleged breach of contract occurred in the Philippines, as John failed to deliver the goods according to the agreed-upon terms.
2. Scenario 2: The alleged breach of contract occurred in Spain, as Maria failed to pay the agreed-upon purchase price for the goods.
3. Scenario 3: The alleged breach of contract occurred during the transportation of the goods from the Philippines to Spain, leading to damage to the goods.

Determine which law, either Philippine law or Spanish law, should apply to each scenario and provide a brief explanation for your chosen answer.