Facts:
Minoru Fujiki, a Japanese national, married Filipino citizen Maria Paz Galela Marinay in the Philippines on January 23, 2004. The couple could not live together in Japan due to objections from Fujiki’s parents, resulting in a loss of contact over time. Marinay subsequently entered into another marriage with Shinichi Maekara, another Japanese national, on May 15, 2008 in Quezon City, despite her first marriage to Fujiki not being dissolved. Marinay moved to Japan with Maekara but later claimed to have experienced physical abuse.
Marinay reestablished contact with Fujiki, and with his assistance, she received a judgment from a family court in Japan declaring her marriage to Maekara as void on the grounds of bigamy. On January 14, 2011, Fujiki filed a petition in the RTC for the judicial recognition of this foreign judgment, seeking to have the marriage between Marinay and Maekara declared void ab initio under Philippine law and to have this annotated in the civil registry records.
The Regional Trial Court (RTC) dismissed the petition based on improper venue and Fujiki’s lack of standing as a petitioner, citing provisions from the Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages (A.M. No. 02-11-10-SC), which generally stipulates that only a husband or a wife in the marriage in question can file such a petition. Fujiki filed a motion for reconsideration, which the RTC denied, leading to this petition for review in the Supreme Court of the Philippines.
Issues:
1. Applicability of A.M. No. 02-11-10-SC to a petition for recognition of a foreign judgment.
2. Whether the husband from a prior marriage can file a petition to recognize a foreign judgment annulling a subsequent marriage on grounds of bigamy.
3. Can the RTC recognize the foreign judgment in a proceeding for cancellation or correction of entries in the Civil Registry under Rule 108?
Court’s Decision:
The Supreme Court granted the petition by Fujiki, reversing and setting aside the RTC’s dismissal of the petition. It reinstated the RTC petition, directing it to proceed with further proceedings in conformance with the Supreme Court’s decision. The Court ruled that A.M. No. 02-11-10-SC does not apply to petitions for recognition of foreign judgments concerning the status of a marriage where one of the parties is a foreign citizen.
The Court went issue by issue, holding that:
1. Philippine courts should recognize foreign judgments as a matter of comity, limiting their review to determining whether the judgment is consistent with domestic policy or whether an extrinsic ground for repelling the foreign judgment exists.
2. The prior spouse has the interest and legal standing to challenge the bigamous marriage and can invoke the jurisdiction of Philippine courts to recognize a foreign judgment annulling such a marriage.
3. The recognition can be made in a special proceeding for cancellation or correction of entries in the civil registry under Rule 108.
Doctrine:
The Supreme Court established that the provisions under A.M. No. 02-11-10-SC (the Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages) do not apply to petitions for recognition of foreign judgments relating to the status of a marriage involving a foreign citizen. Furthermore, it held that a foreign judgment annulling a bigamous marriage may be recognized in a special proceeding under Rule 108, without the need for a full trial on the merits, respecting the jurisdiction of the foreign court and maintaining consistency with Philippine public policy.
Class Notes:
– The Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages (A.M. No. 02-11-10-SC) does not apply to the recognition of foreign marital judgments.
– A spouse from a prior marriage has standing to challenge the validity of a subsequent marriage on the ground of bigamy, consistent with Article 35(4) of the Family Code and Article 349 of the Revised Penal Code on bigamy.
– Rule 108 allows for recognition of foreign judgments concerning the civil status of a person, such as marriages, in the civil registry.
– Article 26 of the Family Code allows for the recognition of foreign divorce decrees in the Philippines to address the legal dilemma faced by a Filipino who is still married under Philippine law, while their foreign spouse is free to remarry under the laws of another jurisdiction.
– The recognition of a foreign judgment annulling a bigamous marriage does not preclude prosecution for bigamy under Philippine law.
Historical Background:
The case is set against the background of the Philippines’ legal system, which does not have a law on divorce but recognizes foreign divorce decrees under certain circumstances, as stated in Article 26 of the Family Code. This legal principle attempts to balance the Philippines’ non-recognition of divorce with its obligations under international comity to recognize foreign judgments affecting Filipinos who have marital ties with foreign nationals. The case also reflects the unique intersection of the Family Code, the Revised Penal Code on bigamy, and the Rules of Court in the context of transnational marriages and the recognition of foreign judicial decrees.
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