Case Summary (G.R. No. L-68470)
Petitioner’s Challenge
Alice Reyes Van Dorn filed a petition for certiorari and prohibition to annul two interlocutory orders denying (1) her motion to dismiss the accounting suit and (2) her motion for reconsideration. She argued that the Nevada divorce decree, which declared no community property, barred respondent’s claim.
Respondent’s Claim
Richard Upton maintained that Philippine public policy against absolute divorce and local prohibition of foreign decrees affecting domestic property relations rendered the Nevada divorce ineffective in Philippine courts. He contended that Philippine jurisdiction over property on its soil could not be divested by a foreign judgment.
Relevant Dates and Procedural Posture
- Marriage in Hong Kong: 1972.
- Children’s births: April 4, 1973 and December 18, 1975.
- Nevada divorce decree: 1982.
- Civil Case No. 1075-P filed in Pasay: June 8, 1983.
- Orders denying motions: September 15, 1983 and August 3, 1984.
- Supreme Court decision: October 8, 1985.
Applicable Law
- Constitution: 1973 Philippine Constitution (decision before 1990).
- Civil Code: Article 15 (nationality principle) and Articles 109 et seq. (spousal obligations).
- Philippine public policy proscribing absolute divorce for nationals.
Fundamental Issue
Whether a valid foreign divorce decree, accompanied by a representation of no community of property, estops a party from litigating conjugal property rights in Philippine courts.
Facts Determining Jurisdiction and Validity of the Nevada Decree
- The Nevada court obtained personal jurisdiction over both spouses: petitioner appeared personally; respondent empowered attorneys by signed power of attorney expressly disclaiming any community property or obligations.
- The Nevada decree dissolved the marriage bond under American law, extinguishing marital status and rights to seek conjugal property.
Supreme Court’s Rationale
- Estoppel by Prior Judgment: Respondent’s representation in the Nevada proceedings that no community property existed binds him. He cannot later assert spousal rights over Philippine assets.
- Recognition of Foreign Divorce: Although Philippine nationals are subject to the ban on absolute divorce domestically, aliens may secure divorces abroad; such decrees are recognized if valid under their national law and not contrary to local public policy.
- Prohibitory Laws and Public Policy: The petition did not require determining the marital property regime; the decisive factor was the Nevada decree’s effect under American l
Case Syllabus (G.R. No. L-68470)
Parties and Background
- Petitioner Alice Reyes Van Dorn is a Philippine citizen who married private respondent Richard Upton, a United States citizen, in Hong Kong in 1972.
- After their marriage, the spouses established residence in the Philippines and had two children born on April 4, 1973 and December 18, 1975.
- The parties obtained a divorce in Nevada in 1982, wherein they represented there was “no community of property” or “community obligations.”
- Petitioner subsequently remarried in Nevada to Theodore Van Dorn.
Procedural History
- On June 8, 1983, respondent Upton filed Civil Case No. 1075-P before the Regional Trial Court, Branch CXV, Pasay City, claiming that petitioner’s business (the Galleon Shop in Ermita, Manila) was conjugal property and seeking management rights and an accounting.
- Petitioner moved to dismiss on the ground that respondent was estopped by the Nevada divorce decree, which had already adjudicated that no community property existed.
- The trial court denied the Motion to Dismiss on September 15, 1983, and likewise denied petitioner’s Motion for Reconsideration on August 3, 1984.
- Petitioner brought a Petition for Certiorari and Prohibition in the Supreme Court to annul these interlocutory orders.
Issue
- Whether the Nevada divorce decree, acknowledging the absence of community property, bars private respondent from claiming management rights and an accounting of the alleged conjugal property located in the Philippines.
Petitioner's Contentions
- Respondent is estopped by his own represent