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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 Presumptionf. Lex Fori

Question

Subject: Choice of Law - Lex Fori

Alex, a resident of the Philippines, entered into a contract with Bianca, a resident of Japan, for the sale of a rare collector's item. The contract was signed and executed in the Philippines, but the item was to be delivered to Bianca in Japan. There was a dispute between Alex and Bianca regarding the performance of the contract. Alex filed a lawsuit in the Philippines seeking specific performance of the contract, while Bianca filed a counterclaim in Japan for damages.

Considering the scenario above, discuss the following:

  1. What is the doctrine of Lex Fori and how does it apply in this case?
  2. Which country's law should govern the contract between Alex and Bianca, and why?
  3. Discuss any potential conflicts of laws that may arise in this case and how they should be resolved.



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Bar Review Question: Subject: Choice of Law - Lex Fori Alex, a resident of the Philippines, entered into a contract wit