5/4/2021 E-Library - Information At Your Fingertips: Printer Friendly 161 SCRA 122, 133-134, May 6, 1988. [35] The transcript of stenographic notes states that the original copies of the divorce decrees were presented in court (TSN, December 16, 1998, p. 5; records, p. 176), but only photocopies of the same documents were attached to the records (Records, Index of Exhibits, p. 1.). [36] TSN, December 15, 1998, p. 7; records, p. 178. [37] TSN, December 16, 1998, p. 7; records, p. 178. [38] People v. Yatco, 97 Phil. 941, 945, November 28, 1955; Marella v. Reyes, 12 Phil. 1, 3, November 10, 1908; People v. Diaz, 271 SCRA 504, 516, April 18, 1997; De la Torre v. Court of Appeals, 294 SCRA 196, 203-204, August 14, 1998; Maunlad Savings & Loan Asso., Inc. v. Court of Appeals, GR No. 114942, November 27, 2000, pp. 8-9. [39] Art. 15, Civil Code. [40] Joaquin Bernas, The 1987 Constitution of the Republic of the Philippines: A Commentary, 1996 ed., p. 566. [41] Ricardo J. Francisco, Evidence: Rules of Court in the Philippines, second edition, p. 382. [42] Ibid., p. 384. [43] Wildvalley Shipping Co., Ltd. v. Court of Appeals, GR No. 119602, October 6, 2000, p. 7. [44] Francisco, p. 29, citing De los Angeles v. Cabahug, 106 Phil. 839, December 29, 1959. [45] 27A CJS, 15-17, §1. [46] Ibid., p. 611-613, §161. [47] 27A CJS, 625, §162. [48] Rollo, p. 36. [49] "SEC. 48. Effect of foreign judgments or final orders.--The effect of a judgment or final order of a tribunal of a foreign country, having jurisdiction to render the judgment or final order is as follows: xxx xxx xxx https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/52783 12/13