11/9/2020 E-Library - Information At Your Fingertips: Printer Friendly judgment granting the divorce, but also the alien spouse's national law. This rule is rooted in the fundamental theory that Philippine courts do not take judicial notice of foreign judgments and laws. As explained in Corpuz v. Sto. Tomas:[43] The starting point in any recognition of a foreign divorce judgment is the acknowledgment that our courts do not take judicial notice of foreign judgments and laws. Justice Herrera explained that, as a rule, "no sovereign is bound to give effect within its dominion to a judgment rendered by a tribunal of another country." This means that the foreign judgment and its authenticity must be proven as facts under our rules on evidence, together with the alien's applicable national law to show the effect of the judgment on the alien himself or herself. The recognition may be made in an action instituted specifically for the purpose or in another action where a party invokes the foreign decree as an integral aspect of his [or her] claim or defense.[44] (Citations omitted) Both the foreign divorce decree and the foreign spouse's national law, purported to be official acts of a sovereign authority, can be established by complying with the mandate of Rule 132, Sections 24[45] and 25[46] of the Rules of Court: Under Sections 24 and 25 of Rule 132, on the other hand, a writing or document may be proven as a public or official record of a foreign country by either (1) an official publication or (2) a copy thereof attested by the officer having legal custody of the document. If the record is not kept in the Philippines, such copy must be (a) accompanied by a certificate issued by the proper diplomatic or consular officer in the Philippine foreign service stationed in the foreign country in which the record is kept and (b) authenticated by the seal of his office.[47] (Citations omitted) Here, the Regional Trial Court ruled that the documents petitioner submitted to prove the divorce decree have complied with the demands of Rule 132, Sections 24 and 25. [48] However, it found the copy of the Japan Civil Code and its English translation insufficient to prove Japan's law on divorce. It noted that these documents were not duly authenticated by the Philippine Consul in Japan, the Japanese Consul in Manila, or the Department of Foreign Affairs.[49] Notwithstanding, petitioner argues that the English translation of the Japan Civil Code is an official publication having been published under the authorization of the Ministry of Justice[50] and, therefore, is considered a self-authenticating document.[51] Petitioner is mistaken. In Patula v. People,[52] this Court explained the nature of a self-authenticating document: The nature of documents as either public or private determines how the documents may be presented as evidence in court. A public document, by virtue of its official or sovereign character, or because it has been acknowledged before a notary public (except a notarial will) or a competent https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/65383 4/11