Question

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

Scenario:

In a civil case involving a contract dispute between a Philippine company (Plaintiff) and a foreign company (Defendant), the issue of which law to apply arises. The contract was executed in the Philippines, and the performance of the obligations was to take place in the Philippines as well. However, the contract contains a clause stipulating that any dispute arising from the contract shall be governed by the laws of another country.

Question:

1. Discuss the principle of lex fori in relation to the choice of law in the given scenario. (5 points)
2. Determine the appropriate law to be applied in resolving the contract dispute and explain the basis for your choice. (10 points)