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Facts: In Singapore, a forklift operator employed by a Philippine-based contractor negligently fails to secure a suspended steel beam. The beam collapses and injures a passerby, a resident of Manila. The passerby sues the contractor in a Philippine court located in Manila. (a) Identify the doctrine that determines which law governs delictual liability and state the controlling rule. (b) Distinguish Lex loci delicti from other conflict-of-laws rules and indicate which rule governs in this case and why. (c) Apply the rule to the facts and state which law governs liability and damages, and whether the contractor may be vicariously liable for the operator’s act under Philippine law.