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1.

Lex domicilii
It is the national law or the domicillary law. The law of the country of domicile determines such
matters as capacity to make a will in respect of personal property, the validity of such a will,
succession to personal property, consent to marriage, and the proper law of a marriage contract
or settlement.

2. Lex fori
Lex Fori means the law of the court or forum. It
governs all procedural matters as distinguished from substantive rights.
The forms of remedies, the modes of proceeding, and the execution of judgments, are to be
regulated solely and exclusively, by the laws of the place where the action is instituted or as the
civilians uniformly express it, according to the lex fori.

3. Lex loci
Lex loci is the law of the place. It is the law of the state or the nation where the matter in
litigation transpired. It is the principle that the law of the place giving rise to particular rights is
the law that governs the rights of parties to a legal proceeding.

4. Lex loci contractus


It is the law of the place where the contract is made. Lex loci contractus is often the proper law
to decide contractual disputes. This principle is applicable when there arises a conflict of laws
with regard to a contract and when the validity of a contract is in question.
It is also the law of the place where the contract is to be governed (place of performance) which
may or may not be the same as that of the place where it was made

5. Lex loci rei sitae


Law of the place where the thing (is situated). The title to realty or question of real estate law
can be affected only by the law of the place where it is situated

6. Lex situs
The law of the place where the property is situated. It governs almost everything that concerns
real property: formalities for their alienation, the capacity to encumber or otherwise dispose of
them, and so forth. In the Philippines, this rule applies to both real and personal properties.

7. Lex loci actus


The law of the place where a legal action takes place. In other words, it is the law of the place
where the act occurred that gave rise to the legal claim.

8. Lex loci celebrationis


It is the law of the place of celebration or execution, Governs generally all transactions insofar as
formalities or solemnities are concerned. One important exception to this rule is whenever
property is involved, in which case, it is the lex situs that should control.
9. Lex loci solutionis
Latin term for law of the place of solution. The law of the country where the agreement is to be
performed. It is the law of the place where payment or performance of a contract is to be made.

10. Lex loci delicti commissi


The law of the place where the delict [tort] was committed. When a case having foreign
elements comes before a court the court applies private international law. In such
circumstances, lex loci delicti commissi is one of the possible choice of law rules applied to cases
arising from an alleged tort.

11. Lex mercatoria


Latin term for merchant law. It evolved as a system of custom and practice, which was enforced
through a system of merchant courts along the main trade routes. It functioned as the
international law of commerce. It emphasized contractual freedom, alienability of property.

12. Lex non scripta


It is the unwritten common law, which includes general and particular customs and particular
local laws. It refers to a time before written reports existed, when rules and principles were
conveyed by example and retained by memory alone.

13. Lex patriae


Law of nationality. It is a civil law choice of law rule to test the status and capacity of the parties
to the case. It is also the system of public law applied to a lawsuit if a choice is to be made
between two or more laws that would change the outcome.

14. Read and Digest (Topic: Proving foreign laws)

ATCI Overseas Corporation Vs. Amalia G. Ikdal

G.R. No. 178551 October 11, 2010


15. Read and Digest (Topic: Proving foreign laws):
Edi-staff Builders International v. NLRC GR No. 145587, Oct. 26, 2007
16. Read and Digest (Topic: Proving foreign laws):
Asiavest Limited v. CA GR No. 128803 September 25, 1998-
17. Read and Digest (Topic: Proving foreign laws):
Manufacturers Hanover Trust Co. v. Guerero GR No. 136804, February 19, 2003
18. Read and Digest (Topic: Proving foreign laws):
Wildvalley Shipping Co., Ltd. Vs. Court Of Appeals And Philippine President Lines In G.R. No.
119602 October 6, 2000
19. Read and Digest (Topic: Proving foreign laws):
Pakistan International Airlines Corporation, Vs Hon. Blas F. Ople G.R. No. 61594 September 28,
1990
20. Read and Digest (Topic: Proving foreign laws):
Norma A. Del Socorro, Vs. Ernst Johan Brinkman Van Wilsem, GR. No. 193707 December 10,
2014
21. Read and Digest (Topic: Exceptions to the application of the foreign law in conflict problems)
Gerbert Corpuz Vs. Daisylyn Tirol Sto Tomas And The Solgen GR. NO. 186571
22. Read and Digest (Topic: Exceptions to the application of the foreign law in conflict problems)
Fujiki vs Marinay G.R. No. 196049 June 26, 2013
23. Read and Digest (Topic: Exceptions to the application of the foreign law in conflict problems)
Republic v. Marelyn Tanedo Manalo, G.R. No. 221029 April 24, 2018
24. Read and Digest (Topic: Exceptions to the application of the foreign law in conflict problems)
Cadalin vs. POEA, 238 SCRA 721
25. Read and Digest (Topic: Exceptions to the application of the foreign law in conflict problems)
Miciano vs. Brimo, 50 Phil 867 G.R. No. L-22595
26. Read and Digest (Topic: Exceptions to the application of the foreign law in conflict problems)
Dacasin vs. Dacasin GR No. 168785
27. Read and Digest (Topic: Exceptions to the application of the foreign law in conflict problems)
BANK OF AMERICA, NT and SA, vs. AMERICAN REALTY CORPORATION and COURT OF APPEALS,
G.R. No. 133876 December 29, 1999
28. Read and digest the following cases: (Topic: Exceptions to the application of the foreign law in
conflict problems)
LWV Construction Corporation, , V. Marcelo B. Dupo, [G.R. No. 172342 : July 13, 2009]
29.

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