Question

In a dispute involving the sale of a property between two individuals, one domiciled in the United States and the other in the Philippines, the question of which jurisdiction's law applies arises. Consider the following scenario:

1. John, a US citizen, entered into a contract of sale with Maria, a Filipino citizen, for the purchase of a property in the Philippines.
2. The contract specifies that any disputes arising from the agreement would be resolved through arbitration in Manila.
3. Subsequently, a disagreement arises regarding the fulfillment of certain obligations under the contract.
4. John asserts that the laws of the United States should govern the dispute.
5. Maria argues that Philippine law should be applied since the property is situated in the Philippines.

Based on the given scenario, determine which jurisdiction's law should be applied to resolve the dispute and provide a concise and clear explanation of your reasoning, citing relevant legal principles.