G.R. No. 248355 - Rivera vs. Woo Namsun

Maricel L. Rivera (petitioner), a Filipino, married Woo Namsun (respondent), a South Korean national, on April 18, 2007, in Quezon City.
They lived together in South Korea for about a year before their relationship deteriorated due to respondent's abusive behavior.
Petitioner returned to the Philippines in 2008 but went back to South Korea shortly after.
In 2011, petitioner discovered that respondent had filed for divorce, which was granted by the Seoul Family Court on June 14, 2011.
Respondent remarried a Chinese national, Kim Seonyeo, on November 8, 2011.

Petitioner sought to remarry and filed a petition with the Regional Trial Court (RTC) of Quezon City on September 23, 2015, for judicial recognition of the foreign divorce decree.
She submitted evidence, including an Authentication Certificate from the Department of Foreign Affairs (DFA), a Letter of Confirmation from the South Korean Embassy, and the Judgment of Divorce from the Seoul Family Court.
The RTC granted the petition on March 1, 2017, recognizing the divorce and declaring petitioner capacitated to remarry.

The Office of the Solicitor General (OSG) appealed, arguing that petitioner failed to sufficiently prove the foreign divorce decree and the applicable South Korean law.
The CA reversed the RTC decision on March 8, 2019, ruling that petitioner did not comply with the evidentiary requirements under Sections 24 and 25, Rule 132 of the Rules of Court.
Petitioner’s motion for reconsideration was denied by the CA on July 10, 2019.

Whether the foreign divorce decree and the national law of Woo Namsun recognizing his capacity to obtain divorce were proven during trial.
Assuming the foreign divorce decree and the national law of Woo Namsun were not proven, whether the case should be remanded to the trial court for reception of evidence.

The Supreme Court reversed the CA’s decision and remanded the case to the RTC for further proceedings, allowing petitioner to present additional evidence to prove the foreign divorce decree and the applicable South Korean law.