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 ▸ c. Lex Contractus

Question

Subject: Choice of Law and the Doctrine of Renvoi

Scenario:

John, a resident of the Philippines, entered into a contract with Maria, a resident of France, for the purchase of a rare painting. The contract was executed in the Philippines, but the painting is located in France. A dispute arises regarding the performance of the contract, and John decides to file a lawsuit against Maria.

Question:

Which law should the Philippine court apply in determining the validity and enforceability of the contract? Explain your answer with reference to the Doctrine of Renvoi.

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