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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 ▸ d. Lex Loci Celebrationis

Question

Subject: Choice of Law and Lex Loci Celebrationis

Scenario:

Alex and Maria, both Filipino citizens, got married in Hawaii. After several years of marriage, they decided to file for divorce. Alex wants to file for divorce in the Philippines, while Maria wants to file for divorce in Hawaii. They seek legal advice to determine which jurisdiction's law should apply.

Question:

Under the doctrine of Lex Loci Celebrationis, which jurisdiction's law should apply to the divorce proceedings of Alex and Maria? Explain the rationale behind your answer.



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Bar Review Question: Subject: Choice of Law and Lex Loci Celebrationis Scenario: Alex and Maria, both Filipino citizen