6/30/2021 E-Library - Information At Your Fingertips: Printer Friendly Constitution. Rules of procedure are promulgated by the Supreme Court, and could very well be abrogated or revised by the high court itself. Yet the Supreme Court is obliged, as are all State Components, to obey the laws of the land, including generally accepted principles of international law which form part thereof, such as those ensuring the qualified recognition and enforcement of foreign judgments. Thus, relative to the enforcement of foreign judgments in the Philippines, it emerges that there is a general right recognized within our body of laws, and affirmed by the Constitution, to seek recognition and enforcement of foreign judgments, as well as a right to defend against such enforcement on the grounds of want of jurisdiction, want of notice to the party, collusion, fraud, or clear mistake of law or fact.[48] (Italics supplied.) It is an established international legal principle that final judgments of foreign courts of competent jurisdiction are reciprocally respected and rendered efficacious subject to certain conditions that vary in different countries.[49] "In the recognition of foreign judgments, Philippine courts and incompetent to substitute their judgment on how a case was decided under foreign, law."[50] They are limited to the question of whether to extend the effect of the foreign judgment in the Philippines.[51] Thus, in a foreign judgment relating to the status of adoption involving a citizen of a foreign country, Philippine courts will only decide whether to extend its effect to the Filipino party. For this purpose, Philippine courts will only determine: (1) whether the foreign judgment is contrary to an overriding public policy in the Philippines; and (2) whether any alleging party is able to prove an extrinsic ground to repel the foreign judgment, i.e., want of jurisdiction, want of notice to the party, collusion, fraud, or clear mistake of law or fact.[52] Absent any inconsistency with public policy or adequate proof to repel the judgment, Philippine courts should, by default, recognize the foreign judgment as part of the comity of nations.[53] For Philippine courts to judicially recognize a foreign judgment relating to the status of an adoption where one of the parties is a citizen of a foreign country, the petitioner only needs to prove the foreign judgment as a fact under the Rules of Court. Thus, as held in Fujiki v. Marinay, et al.:[54] x x x To be more specific, a copy of the foreign judgment may be admitted in evidence and proven as a fact under Rule 132, Sections 24 and 25, in relation to Rule 39, Section 48(b) of the Rules of Court. Petitioner may prove the Japanese Family Court judgment through (1) an official publication or (2) a certification or copy attested by the officer who has custody of the judgment. If the office which has custody is in a foreign country such as Japan, the certification may be made by the proper diplomatic or consular officci1 of the Philippine foreign service in Japan and authenticated by the seal of office.[55] Accordingly, the Court deems it proper to remand the case to Branch 192, RTC, Marikina City for further proceedings. To emphasize, recognition and enforcement of a https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66689 9/13