Title
Basa-Egami vs. Bersales
Case
G.R. No. 249410
Decision Date
Jul 6, 2022
Filipina petitioner seeks recognition of Japanese divorce decree under Philippine law; Supreme Court remands case for proof of Japanese divorce law.

Case Summary (G.R. No. 241309)

Key Dates and Applicable Law

Relevant dates in the record: marriage on 18 May 1994; Japanese divorce reported and accepted on 03 April 2008; RTC decision granting recognition on 07 December 2016; CA decision reversing on 25 March 2019 and CA resolution on 22 July 2019; petition to the Supreme Court decided in 2022. The constitutional basis is the 1987 Philippine Constitution. Governing statutes and rules cited include Article 26(2) of the Family Code, Rule 65 (special civil action for certiorari), Rule 45 (petition for review on certiorari), and Rule 132, Sections 24 and 25 of the Rules of Court concerning proof of foreign judgments and foreign law.

Factual Background

Petitioner married Japanese national Hiroshi Egami on 18 May 1994. The marriage de facto ended by October 2006, and the spouses obtained a divorce in Japan, reflected in the Family Register and a Certificate of Acceptance/Receiving on 03 April 2008. Petitioner sought recognition of the foreign divorce in the RTC of Quezon City to enable remarriage.

Documentary and Testimonial Evidence Presented

Petitioner testified and introduced: (1) a certified Notification/Report of Divorce authenticated by the Philippine Consulate in Osaka; (2) the Family Register of Egami showing the fact of divorce, certified by Japanese officials and authenticated by Philippine consular authorities; (3) a Certificate of Acceptance/Receiving of the divorce report, similarly certified and authenticated; and (4) excerpts from a book titled The Civil Code of Japan, certified and notarized in Japan and authenticated by the Philippine consul.

RTC Ruling and Reasoning

The RTC (Branch 86, Quezon City) granted recognition of the Japanese divorce. It found petitioner satisfied Article 26(2) requirements, credited the authenticated Notification of Divorce and Certificate of Acceptance as proof of the divorce, relied on Japan’s Civil Code provisions to conclude the marriage was dissolved and the parties restored to unmarried status, and rejected the OSG’s contention that the divorce was mutual and therefore not covered.

Court of Appeals Decision

On appeal, the CA reversed and set aside the RTC’s decision and dismissed the petition for recognition. The CA concluded that petitioner failed to properly plead and prove the foreign law governing the divorce, and therefore the divorce could not be recognized under Philippine law despite documentary proof of the divorce report and acceptance certificate.

Issues Presented to the Supreme Court

The Supreme Court identified the issues: (1) whether the petition for certiorari under Rule 65 was a proper recourse or should have been a Rule 45 appeal; (2) whether Philippine courts should recognize a divorce by mutual consent obtained by an alien spouse abroad; (3) whether petitioner complied with Rules of Court in proving the fact of divorce and the foreign national law; and (4) whether the petition was meritorious.

Procedural Jurisdiction and Proper Remedy

The Court explained that certiorari under Rule 65 ordinarily is improper when an appeal under Rule 45 is available. A final CA judgment is generally appealable to the Supreme Court by a verified petition for review under Rule 45, and certiorari is reserved for correcting jurisdictional errors or grave abuse of discretion. Petitioner filed under Rule 65 and did so beyond the 15‑day prescriptive period for a Rule 45 petition. Although the petition could have been dismissed as an improper remedy, the Court exercised its discretion to give due course to the petition in the interest of substantial justice and to address the merits because rigid application of procedural rules would have produced manifest injustice in the circumstances.

Recognition of Divorce by Mutual Consent under Article 26(2)

On the merits, the Court reaffirmed the purpose of Article 26(2): to prevent a Filipino from remaining married in the Philippines when an alien spouse has validly obtained a foreign divorce recognized by the alien’s national law. The Court rejected the OSG’s narrow construction that Article 26(2) requires that the alien spouse alone must have initiated the divorce. The Court relied on controlling precedents (notably Republic v. Manalo and Racho v. Tanaka) holding that Article 26(2) requires only that a divorce be validly obtained abroad under the alien spouse’s national law, irrespective of who initiated the proceedings. Accordingly, a divorce by mutual consent between a Filipino and an alien may be recognized in the Philippines if the documentary and legal requirements are met.

Proof of the Fact of Divorce

The Court acknowledged the strict evidentiary requirements under the Rules of Court because Philippine courts do not take judicial notice of foreign judgments or foreign laws. Under Rule 132, Sections 24 and 25, a foreign official record not kept in the Philippines must be accompanied by a certificate from the appropriate Philippine diplomatic or consular officer and authenticated by the seal of that office. While petitioner did not submit the Japanese divorce decree itself, the Court held that authenticated documents such as the Certificate of Acceptance/Receiving of a divorce report and the Family Register—properly certified and authenticated—are admissible and may constitute sufficient proof of the fact of divorce, citing Racho and Moraña decisions that accepted similar documentary proof where the divorce was effected administrative ly rather than by a judicial decree.

Failure to Prove Foreign Law (Japanese Law)

Despit

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