If the tables have turned, other countries will follow as well

We are only bound by commity by the understanding that other countries will do the same

Conflicts there is no obligation.

When you need to apply a Saudi Law, it is not based on a treaty.

Comity is the association of other countries for their mutual benefit.

Why do we have conflicts of law everywhere? Why is it scattered. No codifications?

- Civil law came from Spanish Civil code.

- RPC also came from Spanish laws
- Constitution is Ango-american
- Conflicts is sourced from diff branch of laws and they also come from different sources.
- It’s a clash between Anglo-american and Roman law
- Our Jurisdiction is considered as one of the most unique combination of conflicts of laws.
- When we study Conflicts, it is more complex than in other nations

Common law

- Based on customs
- Everything that has been ordered, they are based from a local jury
- These judges were guided by customs or old cases
- The birth of stare decisis
- If another judge ruled this way, stare decises will follow

Civil law

- Unified
- In our case, technically there is no more distinction if we have civil law or common law
- All laws are codified
- Except for one principle, custom

Ignore na dapat yung difference ng common law and civil law