Question

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

Scenario:

Marie, a Filipino citizen, owns a property in the Philippines. She also has a property in the United States. Marie passed away without leaving a will.

Upon her death, a dispute arises among her heirs regarding the applicable law that should govern the succession of her properties. Some heirs argue that Philippine law should govern both properties because Marie was a Filipino citizen. However, others argue that US law should govern the property in the United States because it is located there.

Considering the scenario, discuss:

1. The doctrine of lex rei sitae and its application in determining the applicable law to govern the properties of Marie;
2. The potential conflict between the doctrine of lex rei sitae and the doctrine of renvoi, and how it can impact the determination of applicable law; and
3. The relationship between the doctrine of processual presumption and the determination of applicable law in this case.