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Main Anchor: Good day, Philippines!

For our breaking news today, the Supreme Court is about to


release its judgement on the case of Qatar Airways vs. Miranda Kerr. We have our field reporter Bea
Cadorna to give us an update of the case.

Field Reporter: Yes, Hanna. We are here today at the Supreme Court with Atty. to give us her legal
opinion about the case.

Good day, atty!

Atty: Good day, Bea.

Field Reporter: What do you think will be the outcome of the case?

Atty: I think that the court will decide in favor of the plaintiff.

Reporter: Why do you think so?

Atty: Because the main issue here is whether or not the Philippine law or Saudi Arabian law applies
considering there are various foreign elements involved.

The respondent is a corporation formed and organized under Saudi Arabian law, while the plaintiff is a
Filipino citizen.

The tortious act happened in Saudi, while the employment contract was executed here in the
Philippines.

Based on these factors, it is my opinion that the court should apply the most significant relationship rule

Reporter: What do you mean by most significant relationship rule?

Atty: In tort cases, two approaches can be applied by the court. First is the lex loci delicti or the vested
rights doctrine. This approach employs the law of the place of the injury. The second approach is the
most significant relationship rule.

Under the most significant relationship rule, an examination is made as to what state has the most
connection to a case. According to the Restatement (Second) of Conflict of laws, the points of contact
are the following:

- The place where the injury occurred


- The place where the conduct causing the injury occurred
- The domicile, residence, nationality, place of incorporation, and place of business of the parties
- The place where the relationship, if any, between the parties is centered

Reporter: So why apply the most significant relationship approach?

Atty: Considering the facts in this case, Philippines has the most significant points of contact.

The court should apply the Philippines laws because it is in the Philippines where the relationship
between the parties was centered.
It is in the Philippines where the employment contract was entered into. By virtue of the employment,
the events transpired during her many travels particularly from Manila to Saudi Arabia, and vice versa.

More importantly, it is in the Philippines where the she relied in good faith that her employer will
protect her.

Reporter: Why not apply the lex loci delicti approach?

Atty: While some courts favor its simplicity and ease in application, a lot of courts disfavor it because it
is inflexible and it does not meet the needs and complexities of modern litigation. Such as in this case,
where there are various foreign elements to be considered.

What is important here is the place where the over all harm to the person’s reputation and social
standing is lodged. Therefore, it is not without basis to apply the Philippine law.

Reporter: Thank you atty for the that insightful information.

We just a hope for a favorable decision for our fellow-Filipina that she can get the relief she deserves.
Good evening. This is Bea Cadorna, reporting. Back to Studio.