Court is faced with foreign element:

1. Dismissed- forum non-convenience- prevent abuse – unfairness – promote fair fight and
immediate action.
- Client Filipino BPO affiliated with Australian company.
- Services rendered PH, payment in Australia.
- FORUM INCOVENIENT. BOTH ARE AUSTRALIAN COMPANIES.

2. Assume Jurisdiction
 Follow the nationality
 Foreign laws do not extend beyond the borders where they are issued but with
certain exceptions.
 Art. 16. National Law of the Decedent
o Foreign law must be pleaded and prove
o Prove by official publication, certification from the _________.

We cannot take judicial notice of foreign laws. Hence, FL must be prove.

3. Even if there is a law requires to follow FL the court may not follow such FL.
 Penal in nature
 Reason of public policy
 Procedural; forum related

Vested rights- wherever you go, it follows you.

Local Theory- follow local law.

If court says, this law shall apply, it would be unfair. Hence, grouping theory is made to apply .

INTEREST ANALYSIS-