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Question
Pedro Reyes, a Filipino citizen, owns a parcel of land in Zamboanga City. He sells the land to Omar Al-Hassan, a foreign national. The deed of sale is executed in Tokyo, Japan under Japanese law and is forwarded to the Philippines for registration at the Zamboanga Registry of Deeds. (a) Which law governs the transfer of ownership of land situated in the Philippines—lex situs (the law of the place where the property is located) or lex fori (the forum’s law)? (b) Which law governs the formality of the deed and its registration—lex fori or Philippine substantive law? (c) Based on the governing rules, is the sale registrable in Zamboanga? Explain briefly.