Case Digest (G.R. No. 70451) Core Legal Reasoning Model
Facts:
Luzviminda Dela Cruz Morisono (petitioner) and Ryoji Morisono (respondent), a Japanese national, were married in Quezon City on December 8, 2009. They lived together in Japan for over a year but did not have any children. Their marriage was strained, largely due to Ryoji's infidelity and their age difference. Subsequently, Luzviminda and Ryoji jointly filed for a "Divorce by Agreement" in Mizuho-Ku, Nagoya City, Japan. The divorce was approved on January 17, 2012, and recorded on July 1, 2012. Following this, Luzviminda petitioned the Regional Trial Court (RTC) of Quezon City, Branch 105, for the recognition of the foreign divorce decree to have her former husband’s surname removed from her passport and to reacquire the capacity to remarry. The RTC set the case for hearing, and with no opposition except from the government, Luzviminda presented evidence ex-parte. The Public Prosecutor did not object to the admissibility of her evidence. However, on July 18, 2016,
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Case Digest (G.R. No. 70451) Expanded Legal Reasoning Model
Facts:
- Marriage and Family Life
- Luzviminda Dela Cruz Morisono (petitioner), a Filipino citizen, married Ryoji Morisono (respondent), a Japanese national, in Quezon City on December 8, 2009.
- The couple lived together in Japan for one year and three months but did not have children.
- Their marriage was marred by constant quarrels, largely due to Ryoji's philandering and the significant age difference between the spouses.
- Divorce Proceedings Abroad
- Luzviminda and Ryoji submitted a "Divorce by Agreement" petition before the City Hall of Mizuho-Ku, Nagoya City, Japan.
- The divorce was approved on January 17, 2012, and duly recorded with the Head of Mizuho-Ku on July 1, 2012.
- Petition for Recognition in the Philippines
- Luzviminda filed a petition for recognition of the foreign divorce decree before the Regional Trial Court (RTC) of Quezon City to allow cancellation of her former husband's surname in her passport and for the capacity to remarry under Philippine law.
- The RTC conducted a hearing where Luzviminda’s evidence was presented ex-parte due to lack of opposition except from the government, and her formal offer of evidence was admitted.
- RTC Decision
- The RTC denied Luzviminda's petition in its Decision dated July 18, 2016.
- The ruling was based on the nationality principle under Article 15 of the Civil Code and Article 26(2) of the Family Code, which, the RTC held, does not allow a Filipino spouse who procured the foreign divorce to have it recognized.
- The RTC held that since Luzviminda is Filipino and Philippine law does not allow divorce, the foreign divorce decree she procured was not binding domestically.
- Petition for Review
- Luzviminda elevated the case to the Supreme Court via a petition for review on certiorari, contesting the RTC's denial.
Issues:
- Whether the RTC correctly denied Luzviminda’s petition for recognition of the foreign divorce decree obtained with her foreign spouse.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)