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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 Presumptionh. Lex Loci Solutionis

Question

Subject: Choice of Law

Scenario:

A and B are residents of two different countries, with A residing in the Philippines and B residing in the United States. A and B enter into a contract for the sale of goods, with the performance of the contract to occur in the Philippines. The contract does not explicitly stipulate the applicable law.

Question:

  1. Based on the principle of Lex Loci Solutionis, which country's law should govern the contract between A and B? Explain your answer.



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Bar Review Question: Subject: Choice of Law Scenario: A and B are residents of two different countries, with A residin