G.R. No. 46000 - People vs. Baes

On August 17, 1995, petitioner Regie David Tsutsumi (Filipino) married Ayahiro Tsutsumi (Japanese) in Tarlac City, Philippines; they had two children.
On April 11, 2016, by mutual agreement, they obtained a divorce in Japan. A Divorce Certificate issued by the Japanese Embassy in Manila was authenticated by the Philippine Department of Foreign Affairs (DFA) and recorded with the Manila Civil Registry.

Petitioner filed a Petition for Recognition of Foreign Divorce with the Regional Trial Court (RTC) of Tarlac City (Special Proceeding Case No. 5491), offering as evidence:

The Japanese Divorce Certificate and Certificate of Acceptance of Notice of Divorce (with English translations).
Authentication certificates from the Japanese Embassy, DFA, Manila Civil Registry, and translations of the Japanese Civil Code (Articles 763–769).

By decision dated June 27, 2019, RTC Branch 64 granted the petition, recognizing the divorce, declaring petitioner capacitated to remarry, and ordering annotation and registration of the divorce on local records.
The Republic appealed. On January 7, 2021, the Court of Appeals (CA) reversed, ruling evidence and authentication insufficient and foreign law inadequately proven; its November 8, 2021 resolution denied reconsideration.
Petitioner filed a Petition for Review on Certiorari with the Supreme Court.

Whether the petitioner sufficiently proved the fact of her foreign divorce in Japan for recognition under Philippine law.
Whether the petitioner adequately pleaded and proved the relevant Japanese law on divorce to justify application of Article 26(2), Family Code.
Whether the Court of Appeals erred in imposing stricter authentication requirements than those prescribed by Rule 132, Sections 24 and 25 of the Rules of Court.