1.

2. Yes. The will is valid as to its extrinsic validity.

The New Civil Code provides that if a Filipino makes a will abroad, he may comply with the formalities
of Philippine law (lex nationalii) or the lex loci celebrationis (the law of the place where he was at the
time of the execution of the will.
In this case, Ariana, a Filipino, executed her will in North Carolina, USA wherein an oral will made while
the testator’s death is imminent and the circumstances where the testator does not survive in the presence
of two or more witness may be valid. Ariana who is in deathbed complied with the formalities of the
North Carolina USA where she was at the time of the execution of the will. Hence, the oral will executed
by Ariana abroad is valid in the Philippines as to its extrinsic validity.
3. The will is valid so long as it complies with the requisites of a holographic will.

The new civil Code provides that a holographic will must be entirely written, dated, and signed by the
hand of the testator himself, subject to no other form and may be made in or out of the Philippines, and
need not be witnessed.

In this case, Ariana wrote her testamentary wishes in her diary which is considered as a holographic will.
However, for her will to be valid, it must be dated and signed by her because non-compliance there with
will make the will invalid.

4. Yes. The Myanmar adoption proceedings is valid in the Philippines.

Even if the Philippines has no provision of law nor jurisprudence which requires the Philippines to
recognize a foreign decree of adoption, the Rules of court of the philippines allows the Philippines to
recognize such foreign decree of adoption provided the foreign court had jurisdiction to render said
decree; and that there was no want of notice, collusion, extrinsic fraud, or clear mistake of law or fact
leading to the foreign decree of adoption.
Hence, the adoption proceedings of San Myint in Myanmar is valid in the philippines provided the
foreign court had jurisdiction to render said decree; and that there was no want of notice, collusion,
extrinsic fraud, or clear mistake of law or fact leading to the foreign decree of adoption.
5.
6.

Extrinsic validity Capacity to contract Intrinsic validity

No choice of law clause
has been stipulated
Lex loci celebrationis Personal law of Lex loci intentionis or
china contracting parties lex loci voluntatis
whether
the national law of the
parties in countries
following the
nationality theory, and
by the law of the
domicile in countries
following the
domiciliary theory.
 Choice of law clause Lex loci celebrationis Personal law of Lex loci intentionis or
has been referred to china contracting parties lex loci voluntatis
Philippine law to whether
govern the contact the national law of the
parties in countries
following the
nationality theory, and
by the law of the
domicile in countries
following the
domiciliary theory.

7.

8.

9. whether the respondent contractor has defaulted in the performance of its obligations under the
service contract.

No conflicts rule on essential validity of contracts is expressly provided for in our laws. The rule followed
by most legal systems, however, is that the intrinsic validity of a contract must be governed by the lex
contractus or "proper law of the contract." This is the law voluntarily agreed upon by the parties (the lex
loci voluntatis) or the law intended by them either expressly or implicitly (the lex loci intentionis). The law
selected may be implied from such factors as substantial connection with the transaction, or the
nationality or domicile of the parties.47 Philippine courts would do well to adopt the first and most basic rule
in most legal systems, namely, to allow the parties to select the law applicable to their contract, subject to
the limitation that it is not against the law, morals, or public policy of the forum and that the chosen law
must bear a substantive relationship to the transaction. 

In this case, the laws of Iraq bear substantial connection to the transaction, since one of the parties is the
Iraqi Government and the place of performance is in Iraq. Hence, the issue of whether respondent VPECI
defaulted in its obligations may be determined by the laws of Iraq. However, since that foreign law was
not properly pleaded or proved, the presumption of identity or similarity, otherwise known as
the processual presumption, comes into play. Where foreign law is not pleaded or, even if pleaded, is not
proved, the presumption is that foreign law is the same as ours.

10.