Flashcards Studio

Rosa Dela Cruz, a Filipino seller, owns a parcel of land in Davao City. She enters into a contract of sale with Omega Swiss Co., a Swiss corporation, for the same parcel. The contract is signed in Zurich on August 20, 2024 and provides that the contract shall be governed by Swiss law and that ownership passes to Omega upon full payment. The land remains titled in Rosa’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 Omega’s claimed ownership of the land?