G.R. No. 196049 - Fujiki vs. Marinay

Parties and marriage history
Minoru Fujiki, a Japanese national, married Maria Paz Galela Marinay, a Filipina, on January 23, 2004 in Pasay City, Philippines.
Fujiki’s parents disapproved, preventing Marinay’s relocation to Japan and causing the spouses to lose contact.

Subsequent bigamous marriage and foreign decree
Without dissolving her first marriage, Marinay married Shinichi Maekara (Japanese national) on May 15, 2008 in Quezon City.
Alleged physical abuse by Maekara led Marinay to leave him and reconnect with Fujiki in Japan.
On August 18, 2010, the Japanese Family Court issued a Decree of Absolute Nullity of the Marinay–Maekara marriage on the ground of bigamy (Trial Family Court Decree No. 15, 2009).

Philippine proceeding and RTC dispositions
On January 14, 2011, Fujiki filed in RTC Quezon City (Branch 107) a petition for judicial recognition of the Japanese judgment, declaration that the bigamous marriage was void ab initio under Family Code Arts. 35(4) and 41, and for annotation of the civil-registry entry under Rule 108, Rules of Court.
January 31, 2011: The RTC dismissed the petition sua sponte for improper venue and lack of personality (only “husband or wife” may file under A.M. No. 02-11-10-SC Sec.2(a) and Sec.4) and for non-compliance with Sec.5 requirements (contents, verification, certification, service).
March 2, 2011: The RTC denied Fujiki’s motion for reconsideration, reiterating lack of personality and improper venue, citing Braza v. City Civil Registrar (Rule 108 has no jurisdiction over validity of marriage), and noting defective verification and forum-shopping certification.
On appeal to this Court, the Office of the Solicitor General filed a manifestation supporting Fujiki, citing Juliano-Llave v. Republic (Sec.2(a) inapplicable to bigamy) and Corpuz v. Sto. Tomas (foreign divorce recognition under Rule 108). Marinay did not oppose; Maekara denied abuse.

Whether A.M. No. 02-11-10-SC (Rule on Declaration of Absolute Nullity/Annulment) applies to a petition for recognition of foreign judgment.
Whether the prior spouse (Fujiki) has personality to file for recognition of a foreign judgment annulling a subsequent bigamous marriage.
Whether the RTC can recognize a foreign judgment in a cancellation/correction proceeding under Rule 108, Rules of Court.