Question

Scenario:

Carlos, a resident of the Philippines, entered into a contract with Laura, a resident of France, for the sale of a valuable artwork. The contract did not specify which country's law would govern the agreement. A dispute arises regarding the terms and conditions of the contract.

Question:

Which country's law will govern the contract? Explain the application of the doctrine of lex loci solutionis in determining the applicable law in this case.

Scenario:

Juan, a Filipino citizen, owns a real estate property located in California, USA. He wants to donate the property to his niece, Maria, who is a permanent resident of New York. The donation was executed and notarized in the Philippines. The laws of California do not recognize the formality of notarization for the validity of donations, while the laws of New York require notarization.

Question:

Applying the doctrine of renvoi, what law will govern the validity of the donation? Explain how the doctrine of renvoi operates in this situation, and identify the potential conflicts that may arise in the application of this doctrine.

Scenario:

Anna, a Filipino citizen, filed a complaint against Henry, an American citizen, for breach of contract. The contract was entered into in the Philippines, and the alleged breach occurred in the United States. The Philippine court has jurisdiction over the case. The contract did not specify the governing law.

Question:

Applying the doctrine of processual presumption, which country's law will govern the contract in the Philippine court's determination of the dispute? Explain the application of this doctrine in determining the applicable law and its significance in resolving conflicts of laws issues.