Question

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

You are a judge presiding over a complex international divorce case. The husband, Juan, is a Filipino citizen domiciled in the Philippines, while the wife, Maria, is a French citizen domiciled in France. The couple got married in the Philippines and later moved to France, where they resided for several years. They have decided to file for divorce but cannot agree on which country's law should govern their divorce proceedings. The main issue revolves around the determination of their matrimonial property regime.

Please answer the following question:

1. Under Philippine law, what is the principle governing the determination of the matrimonial property regime of a mixed nationality couple? Discuss the applicable laws, rules, and doctrines.