4/20/2021 E-Library - Information At Your Fingertips: Printer Friendly court gave her an additional opportunity to present evidence through its Order dated December 3, 2013, but she still failed to present the second Divorce Report. Be that as it may, what is at stake is not merely Edna's status, but also her actual marital and family life. In fact, Edna addressed a handwritten letter,[23] dated April 22, 2017, to this Court stating she had been anxiously worried for years about the possible repercussions that Philippine laws may have on her because she, too, had remarried in Japan in November 2014. Considering the recent jurisprudence on mixed marriages under Article 26 of the Family Code, the trial court should have been more circumspect in strictly adhering to procedural rules. For these rules are meant to facilitate administration of fairness and may be relaxed when a rigid application hinders substantial justice.[24] The landmark case of Republic v. Manalo[25] is instructive. Respondent therein offered the following in evidence: 1) Decision of the Japanese Court allowing the divorce; 2) the Authentication/Certificate issued by the Philippine Consulate General in Osaka, Japan of the Decree of Divorce; and 3) Acceptance of Certificate of Divorce by Petitioner and the Japanese national. The Court found though that the Japanese law on divorce was not duly established. It noted, nonetheless, that the existence of the divorce decree was not denied, jurisdiction of the divorce court was not impeached, nor the validity of the foreign proceedings challenged. Thus, the Court exercised liberality and remanded the case for further proceedings, specifically for reception of evidence to prove the relevant Japanese law. In Racho v. Tanaka,[26] therein petitioner was divorced by her Japanese husband. She obtained an authenticated Divorce Certificate from the Japanese embassy which the trial court deemed insufficient to prove the divorce decree. The Court, nonetheless, ruled that the Filipino spouse may be granted the capacity to remarry once it is proven that the foreign divorce was validly obtained and that the foreign spouse's national law considers the dissolution of the marital relationship to be absolute. For it would be unjust to insist, as the OSG did, that petitioner should still be considered married to her foreign husband. The Court noted that justice would not have been served if petitioner was discriminated against by her own country's law. In the recent case of Moraña v. Republic of the Philippines,[27] therein petitioner offered mere printouts of pertinent portions of the Japanese law on divorce and its English translation from a website, sans any proof of its correctness. The lower courts denied her action for recognition of divorce report because she did not present an authenticated Divorce Certificate issued by the Japanese government. The Court acknowledged that petitioner duly proved the fact of divorce but failed to prove the Japanese law on divorce. Relying on Racho[28] and Manalo,[29] the Court nonetheless relaxed procedural requirements and granted the petition. It likewise remanded the case to the trial court for presentation of the pertinent Japanese law on divorce for a new decision on the merits. In Garcia v. Recio,[30] the Court could not determine if respondent, a naturalized Australian citizen, was legally recapacitated to remarry despite the evidence already offered which included: Family Law Act 1975 Decree Nisi of Dissolution of Marriage in the Family Court of Australia; Decree Nisi of Dissolution of Marriage in the Family Court https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66091 6/11