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Question
Maria Santos, a Filipino citizen, owns a parcel of land in Makati City. She sells the land to Kenji Nakamura, a Japanese national. The deed of sale is executed in Paris, France under French law and is then forwarded to the Philippines for registration at the Makati Registry of Deeds. (a) Which law governs the transfer of ownership of land situated in the Philippines—lex situs (the law of the place where the property is located) or lex fori (the forum’s law)? (b) Which law governs the formality of the deed and its registration—lex fori or Philippine substantive law? (c) Based on the governing rules, is the sale registrable in Makati? Explain briefly.