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[19] Petitioner's Memorandum, pp. 8-9; rollo, pp. 242-243.
[20] 43 Phil. 43, 49, March 3, 1922.
[21] Ruben F. Balane, "Family Courts and Significant Jurisprudence in Family Law,"
Journal of the Integrated Bar of the Philippines, 1st & 2nd Quarters, 2001, Vol. XXVII,
No. 1, p. 25.
[22] "ART. 15. Laws relating to family rights and duties, or to the status, condition and
legal capacity of persons are binding upon citizens of the Philippines, even though living
abroad."
[23] "ART. 17.
The forms and solemnities of contracts, wills, and other public
instruments shall be governed by the laws of the country in which they are executed.
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xxx
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"Prohibitive laws concerning persons, their acts or property, and those which have for
their object public order, public policy and good customs shall not be rendered
ineffective by laws or judgments promulgated, or by determinations or conventions
agreed upon in a foreign country."
[24] Tenchaves v. Escano 15 SCRA 355, 362, November 29, 1965; Barretto Gonzalez v.
Gonzalez, 58 Phil. 67, 71-72, March 7, 1933.
[25] "Art. 26.
All marriages solemnized outside the Philippines in accordance with the
laws in force in the country where they were solemnized, and valid there as such, shall
also be valid in this country, except those prohibited under Articles 35(1), (4), (5), and
(6), 36, 37, and 38. (71a)
"Where a marriage between a Filipino citizen and a foreigner is validly celebrated and a
divorce is thereafter validly obtained abroad by the alien spouse capacitating him or her
to remarry, the Filipino spouse shall have capacity to remarry under Philippine law." (As
amended by EO 227, prom. July 27, 1987)
[26] Cf. Van Dorn v. Romillo Jr., 139 SCRA 139, 143-144, October 8, 1985; and Pilapil
v. Ibay-Somera, 174 SCRA 653, 663, June 30, 1989.
[27] Van Dorn v. Romillo Jr., supra.
[28] Ibid., p. 143.
[29] For a detailed discussion of Van Dorn, see Salonga, Private International Law, 1995
ed. pp. 295-300. See also Jose C. Vitug, Compendium of Civil Law and Jurisprudence,
1993 ed., p. 16;
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