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Maria Cruz, a Filipino seller, owns a parcel of land in Iloilo City. She signs a contract of sale with OceanBridge Corp., a Malaysian corporation, for the same parcel. The contract is signed in Kuala Lumpur on January 9, 2029 and provides that ownership passes upon full payment and that the contract shall be governed by Malaysian law. The land remains titled in Maria’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 OceanBridge Corp.’s claimed ownership of the land?