Question

Subject: Choice of Law - Lex Contractus

Scenario:

John, a Filipino citizen, entered into a contract for the sale of goods with Sarah, an American citizen. The contract was executed in the Philippines and the goods were to be delivered to Sarah's address in the United States. However, a dispute arose between them regarding the terms of the contract and the payment obligations. John insists that Philippine law should govern the contract, while Sarah argues that US law should apply.

Question:

Which country's law should govern the contract between John and Sarah, and what factors should be considered in determining the applicable law? Explain your answer.