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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 Presumptionb. Lex Rei Sitae

Question

The Given Subject: Choice of Law, Doctrine of Renvoi, Doctrine of Processual Presumption

In relation to the topic of b. Lex Rei Sitae, consider the following scenario:

Juan, a Filipino citizen, owns a property located in the United States. He executed a will in the Philippines, designating his niece Maria as the sole beneficiary of his property. Unfortunately, Juan passed away while he was in the United States.

Discuss the following:

  1. Which country's law should govern the disposition of Juan's property?
  2. How would the doctrine of renvoi apply in this scenario?
  3. How would the doctrine of processual presumption be relevant?



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