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0 tracked cards Civil Law and Land Titles and Deeds
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A Filipino seller, Maria Reyes, owns a parcel of land in Iloilo City. She signs a contract of sale with Sakura Global Pte. Ltd., a Singapore-based company, for the same parcel. The contract is signed in Singapore on January 15, 2024 and provides that the contract shall be governed by Japanese law and that ownership passes upon full payment. The land remains titled in Maria Reyes’s name in the Philippines. (a) Which law governs the formation and validity of the contract (Lex Contractus) in this scenario? (b) Which law governs the transfer of title to immovable property located in the Philippines (lex rei sitae), and what is the effect of applying both doctrines on Sakura Global Pte. Ltd.’s claimed ownership of the land?

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Clara

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