Friday, December 19, 2008

The Philippine Arbitration Law and the UNCITRAL Model Law

Ii. Major Differences

A) Subject Matter

With respect to the scope of application, the Philippine Arbitration Law differs from the Model Law in that the former applies to any controversy existing between the parties involved. The submission or contract may include questions arising out of valuations, appraisals or other controversies which may be collateral, incidental, precedent or subsequent to any issue between the parties. The Model Law, on the other hand, applies only to international arbitration as provided for in Article 1. Said article states:

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