Question

The Given Subject: Choice of Law

The Given Topic: Lex Loci Celebrationis

Scenario:

Anna, a Filipino citizen, and John, a British citizen, got married in the Philippines. After their wedding, they decided to relocate to the United Kingdom and establish their matrimonial home there. Unfortunately, their marriage turned sour and they decided to file for divorce. Anna wants to file for divorce in the Philippines, citing that they were married in the country. John, on the other hand, wants to file for divorce in the United Kingdom, where they currently reside.

Question:

Which country, the Philippines or the United Kingdom, should have jurisdiction over the divorce proceedings between Anna and John? Discuss the application of the doctrine of Lex Loci Celebrationis in determining the choice of law in this case.