Conflicts of Law I. What law governs the following: a.

A contract of loan between 2 Filipinos entered into in Australia with a Real Estate Mortgage on a land in the Philippines as securit . Philippine law ! the "## provides that real propert is sub$ect to the law of the countr where it is situated b. %apanese gardener case &overned b the proper law of the contract either the le' loci vountatis or le' loci intentionis. !this contract is not governed b the le' situs of the land although the land to be developed is located in the Philippines. What governs is the proper law of the contract between the parties. A contract involving the conve ance of a piece of land in Florida( )*A b two Filipinos in Manila. Florida law !e'trinsic validit and intrinsic validit of the transaction is governed b le' situs +florida law, *ale between 2 Filipinos in #alifornia of shares of stoc-s in Meralco where the vendor transferred the certificate of stoc-s to the bu er at the ti.e of the sale. 2 points ! clarif -o lang -asi /st sabi sa boo- it is either the place where the corporation is incorporated or0 ! 1he proper law of the contract either le' loci voluntatis or le' loci intentionis. In .an cases the place where the certificate is delivered to the bu er. e. *ale to an A.erican b a Filipino e'ecuted in #alifornia on an airplane while fl ing over Pacific 2cean on its wa to Manila. !Proper law of the contract between the parties either le' loci voluntatis or le' loci intentionis because such sa-e is effected through a contractual obligation. f. *ale between 2 .erchants in the Philippines of cargoes fro. #laifornia in an ocean vessel fro. #alifornia to Manila. !Proper law of the contract between the parties either le' loci voluntatis or le' loci intentionis because such sa-e is effected through a contractual obligation. II. /. 2. 5. 3istingusih .ultinational corporation fro. foreign corporation +both doing business in the Philippines, Ma foreign corporation not doing business in the Philippines sue and be sued4 A *panish art collector do.iciled in the Philippines( with no heirs and no will. Who is entitled to the art collection4 +see p. /67, 8. 1wo Filipinos .arried in England. #an the use sterilit as a ground for annul.ent4 +see p. //7, 6. 1wo Filipinos who are first cousins .arried in #alifornia. Is the .arriage valid4 +see p. 9:, ;. Filipino husband got divorced in Me'ico then ca.e bac- to the Philippines with his second wife. #an the first wife file a case4 :. A Filipino doctor in "ew <or- .ade holographic wills and gave nothing to his illegiti.ate child. =e died. a. #an the will be probated4 b. If probated( can the illegiti.ate child as- for his legiti.e4 +see p. /88, >. 3o we have $urisdiction over a #hinese sailor found in possession of shabu while doc-ed in Pier :( Manila4 +see p. /97, 9. What is the effect of a final $udg.ent of a 3istrict court of #alifornia finding a Filipino as owner of an airplane4 + p. 27;, /7. A drives a car. ? was in$ured while he was with A in =ong-ong. A and ? are both Filipinos. a. #an ? file an action against A in Manila4 b. If ? is an A.erican( can he still file a case in Manila4 +*ee ?obcoc- case in the boo-, //. A Musli. business.an and second Filipino wife settles in the Philippines. 1he begot 5 sons. 1he couple die in a .otor accident. Who inherits4 /2. What is the effect of a final $udg.ent in =ong-ong ordering the defendant to pa P/77(777 to plaintiff4 What is the effect in the Philippines: /. 3ivorce b a FIl. =usband in Me'ico with his Filippino wife. 2. 3ivorce b an A.erican husband with his Filipino wife in 1e'as. 5. 3ivorce in #alifornia b a Filipino wife fro. her husband while the for.er was still an i..igrant. After granting the divorce decree( she was naturali@ed in #alifornia. 8. 3ivorce b a for.er Filipino wife of his Filipino husband after she was naturali@ed.

c.

d.

What regi.e governs: /. A Filipino couple who are i..igrants of #alifornia. + p. /76, 2. A Filipina and for.er Filipino husband who was naturali@ed in #alifornia. 5. A Filipino wife and her A.erican husband residing in Manila. 8. A for.er Filipino couple living in #alifornia but are now naturali@ed