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[45] See rollo, p. 146.
[46] Id.
[47] Supra note 33.
[48] Supra note 33 at 655.
[49] RULES OF COURT, Rule 132, Sec. 24. Proof of official record. — The record of public
documents referred to in paragraph (a) of Section 19, when admissible for any
purpose, may be evidenced by an official publication thereof or by a copy attested by
the officer having the legal custody of the record, or by his deputy, and accompanied, if
the record is not kept in the Philippines, with a certificate that such officer has the
custody. If the office in which the record is kept is in a foreign country, the certificate
may be made by a secretary of the embassy or legation, consul general, consul, vice
consul, or consular agent or by any officer in the foreign service of the Philippines
stationed in the foreign country in which the record is kept, and authenticated by the
seal of his office.
Sec. 25. What attestation of copy must state. — Whenever a copy of a document or
record is attested for the purpose of evidence, the attestation must state, in substance,
that the copy is a correct copy of the original, or a specific part thereof, as the case
may be. The attestation must be under the official seal of the attesting officer, if there
be any, or if he be the clerk of a court having a seal, under the seal of such court.
Rule 39, 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:
(a) In case of a judgment or final order upon a specific thing, the judgment or final
order is conclusive upon the title of the thing; and
(b) In case of a judgment or final order against a person, the judgment or final order is
presumptive evidence of a right as between the parties and their successors in interest
by a subsequent title.
In either case, the judgment or final order may be repelled by evidence of a want of
jurisdiction, want of notice to the party, collusion, fraud, or clear mistake of law or fact.
[50] See RULES OF COURT, Rule 132, Sec. 24-25. See also Corpuz v. Santo Tomas,
supra note 36 at 282.
[51] A.M. No. 02-11-10-SC, Sec. 5.
[52] Id., Sec. 6.
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