Question

A lessee entered into a lease agreement with a lessor for a commercial property located in the Philippines. The agreement contained a choice-of-law provision specifying the application of Philippine law. After a few months, a dispute arose between the parties regarding the terms of the lease agreement. The lessor, who was a foreign national, filed a lawsuit in a foreign court seeking to enforce the terms of the lease agreement based on the laws of his home country, which recognized a different set of laws governing lease contracts.

Given the scenario, determine whether the foreign court should apply the choice-of-law provision designating Philippine law or if the court should apply the lex rei sitae principle. Explain your answer and cite relevant laws or jurisprudence to support your position.