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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

Subject: Choice of Law - Lex Contractus


Alex and Ben are parties to a contract for the sale of goods. Alex is a resident of the Philippines, while Ben is a resident of the United States. The contract does not contain any choice-of-law provision.

A dispute arises between Alex and Ben regarding the interpretation and performance of the contract. Alex files a lawsuit in the Philippines, while Ben files a lawsuit in the United States.

Assuming that the Philippines applies the principle of lex contractus:

  1. Which law will govern the contract between Alex and Ben?
  2. What factors will the Philippine court consider in determining the governing law?



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Bar Review Question: Subject: Choice of Law - Lex Contractus Alex and Ben are parties to a contract for the sale of goo