Short answer. Philippine law, unless a marriage settlement stipulates otherwise. Article 80 applies Philippine law to the spouses' property relations regardless of where the wedding was celebrated and where the couple resides. The rule steps aside only where both spouses are aliens, and for certain contracts affecting property abroad.
What the law says
In the absence of a contrary stipulation in a marriage settlement, the property relations of the spouses shall be governed by Philippine laws, regardless of the place of the celebration of the marriage and their residence.
Family Code, Article 80 — Governing Law for Property Relations. Read the full provision →
What the law says
This rule shall not apply: (1) Where both spouses are aliens;
Family Code, Article 80 — Governing Law for Property Relations. Read the full provision →
Where you married and where you live are both irrelevant
The article says so in terms: Philippine law governs regardless of the place of the celebration of the marriage and their residence. A couple who married in Dubai and have lived in Canada ever since are not thereby outside it, and a wedding held abroad does not import the property law of that country by implication. This surprises people who assume the applicable law follows the household. It does not. The connecting factor the Code uses is the parties themselves, which is why one Filipino spouse is enough to bring the marriage's property relations within Philippine law.
The exceptions are narrow and mostly technical
Three situations are carved out. The first is the substantive one: where both spouses are aliens, the rule does not apply — which is the mirror image of the point above, and confirms that a single Filipino spouse triggers it. The other two concern the extrinsic validity of contracts: contracts affecting property not situated in the Philippines and executed in the country where the property is located, and contracts entered into in the Philippines but affecting property in a foreign country whose laws require different formalities. Both are about form — how a document must be executed — rather than about which regime governs the marriage.
The settlement is the only real opt-out
Everything in the article is prefaced by in the absence of a contrary stipulation in a marriage settlement. That is where a couple with a genuine cross-border life can choose something else, and it is a pre-wedding instrument. After the ceremony the opportunity has passed, since the Code requires modifications of the settlements to be made before the celebration of the marriage. Mixed-nationality couples who are still engaged should therefore treat this as a live decision rather than a formality, and those already married should start by finding out whether any settlement was executed and registered.
Governing the regime is not the same as permitting ownership
This is the confusion worth clearing up. Article 80 answers which law characterises the couple's property — what falls into the community, who administers it, how it is liquidated. It says nothing about whether a foreign spouse may own particular assets, and Philippine restrictions on foreign ownership of land are a separate body of law that this provision does not touch or soften. A foreign spouse can be squarely inside a Philippine property regime and still be unable to hold land in his or her own name. If land is part of your picture, that question needs its own advice.