Flashcards Studio

(a) State the doctrine of Lex loci solutionis and the controlling rule for conflicts of laws as it applies to contracts. (b) Distinguish Lex loci solutionis from Lex loci rei sitae and explain which law governs the form and effect of a sale of land in the Philippines when the contract is signed abroad, the deed is executed abroad, but the land lies in the Philippines. (c) Facts: In Cebu, Santos International, a Filipino corporation, sells a parcel of land to NHK Holdings Asia Pte. Ltd., a Singaporean company, for PHP 26,500,000. The sale agreement is signed in Paris; payment is to be made in Paris; the deed will be executed in Bangkok and later presented for registration in the Philippine Register. The land is located in the Philippines and NHK seeks ownership. Apply Lex loci solutionis: (i) which law governs the contract's validity and transfer of title; (ii) may NHK lawfully own the land; (iii) the effect on the title upon registration under Philippine law. Provide a concise conclusion.