Question

Ms. Torres, a Filipino citizen, owns a property in the Philippines. She entered into a contract with Mr. Smith, a British citizen residing in the United Kingdom, for the sale of her property. The contract stipulated that any disputes arising from the contract would be subject to the laws of England.

Unfortunately, a dispute arose regarding the contract and Ms. Torres decided to file a lawsuit in the Philippines. However, the defendant, Mr. Smith, argues that the choice of law clause in the contract should be applied and that the laws of England should govern the dispute.

Based on the given scenario, discuss the applicability of the doctrine of renvoi in determining the choice of law. Can Philippine courts apply the laws of England as chosen by the parties? Support your answer with relevant Philippine laws and Supreme Court decisions.