1. Owing to the nationality principle, all Filipino citizens are covered by the prohibition against absolute divorce. As a consequence of such prohibition, a divorce decree obtained abroad by a Filipino citizen cannot be enforced in the Philippines. To allow otherwise would be to permit a Filipino citizen to invoke foreign law to evade an express prohibition under Philippine law. 2. Nevertheless, the effects of a divorce decree obtained by a foreign national may be extended to the Filipino spouse, provided the latter is able to prove (i) the issuance of the divorce decree, and (ii) the personal law of the foreign spouse allowing such divorce.[14] This exception, found under Article 26(2) of the Family Code, respects the binding effect of the divorce decree on the foreign national, and merely recognizes the residual effect of such decree on the Filipino spouse. It should be emphasized, however, that the prohibition against absolute divorce only applies to Filipino citizens. Accordingly, it cannot be invoked by a foreign national to evade the effects of a divorce decree issued pursuant to his national law. To reiterate, a divorce decree issued by a foreign court remains binding on the foreign spouse in the Philippines, regardless of the party who obtained the same provided that such decree is valid and effective under the foreign spouse's national law. In essence, the applicable rule (whether Article 15 of the Civil Code on one hand, or Article 26[2] of the Family Code on the other), is determined by (i) the law upon which the divorce decree had been issued; (ii) the party who obtained the divorce decree; (iii) the nature of the action brought before the Philippine courts; and (iv) the law governing the personal status of the party seeking relief. The corresponding effect of these determining factors are, in turn, illustrated by the relevant cases involving the issue at hand, decided after the issuance of EO 227: Case Incidents of Divorce Incidents of Action in the Philippines Court's Resolution Pilapil v. IbayDivorce obtained in Somera[15] (Pilapil) Germany by German spouse German spouse filed two (2) complaints charging Filipino spouse with adultery The divorce decree is binding on the German spouse pursuant to the nationality principle. Accordingly, the German spouse lacks standing to file the complaints as "offended spouse", having obtained the divorce decree prior to the filing of said complaints. Republic v. Iyoy[16] (Iyoy) Filipino husband invokes the divorce decree secured by his Filipino wife as additional ground to grant his petition for declaration of nullity The divorce decree cannot be recognized in the Philippines since the Filipino wife obtained the same while still a Filipino citizen, and was, at such time, bound by Philippine laws on family rights and duties, pursuant to the nationality principle. Divorce obtained in the United States by Filipino wife prior to her naturalization as an American citizen