All ▸ Bar 2024 ▸ CIVIL LAW ▸ I. EFFECT AND APPLICATION OF LAWS ▸ M. Conflict of Laws (Civil Code, arts. 15-18) ▸ 2. Choice of Law, Doctrine of Renvoi, Doctrine of Processual Presumption ▸ a. Lex Nationalii

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Subject: Choice of Law, Doctrine of Renvoi, Doctrine of Processual Presumption

In a lawsuit involving a contract dispute between a Philippine company and a foreign company, the parties have conflicting views regarding the applicable law. The Philippine company argues that Philippine law should apply, while the foreign company asserts that the law of its home country should govern the contract.

Based on the principle of lex nationalii, which law should the court apply in determining the validity and enforceability of the contract? Provide a detailed explanation discussing the relevant legal principles and considerations.

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