SOLIS-MANLANGIT, MYTHEL FAITH T.

Conflict of Laws
A compilation of Case Digests
____________________________________________________________________________________________________________

CASE NO. 1
ESTHER VICTORIA ALCALA VDA. DE ALCAÑESES v. JOSE S. ALCAÑESES
G.R. No. 187847 June 30, 2021.

FACTS:
Efren Alcañeses, a Filipino national and a pilot employed by Air Afrique, met his untimely demise in a fatal
plane crash that occurred in Ivory Coast, where he was on duty. Efren is survived by his wife, Esther Victoria
Alcala, and a number of collateral relatives residing in the Philippines. As a result of the plane crash, Kenya Air,
the owner of the aircraft, extended compensation in the amount of US$430,000 to Esther as indemnity for the
loss of Efren.

Following Efren's death, Esther asserted her claim as the sole heir of Efren by executing an Affidavit of
Self-Adjudication. In 2002, Felicidad and Cecilio, acting on behalf of their siblings and nephews/nieces (Efren's
collateral relatives), initiated legal action by filing a Complaint for Partition of Estate and Declaration of Nullity of
Affidavit of Self-Adjudication and Damages with the Regional Trial Court of Lucena City.

The Regional Trial Court, after due proceedings, rendered a decision in favor of Felicidad and Cecilio,
declaring the Affidavit of Self-Adjudication null and void and ordering that half of Kenya Air's indemnity amount
be distributed to Efren's collateral relatives. Subsequently, Esther appealed the decision to the Court of Appeals,
which affirmed the trial court's ruling with modification.

The Court of Appeals held that Esther is entitled to three-fourths of Efren's estate, with the remaining
one-fourth going to his collateral relatives. Additionally, it determined that property exclusively acquired by Efren
during the marriage should be equally divided between Esther and his collateral relatives. Esther sought
reconsideration from the Court of Appeals, but her motion was denied in a resolution dated May 11, 2009.
Dissatisfied with the decision of the Court of Appeals, Esther filed a Petition for Review on Certiorari before the
Supreme Court.

ISSUE: Should the Philippine law apply to the case?

RULING:

No. The Supreme Court ruled that the law of the state with the most connection or interest to the case
should apply, regardless of where the case is filed. It elucidated the principles guiding choice-of-law
determinations, emphasizing the significance of factors such as the parties' nationality, the place where the tort
occurred, the intention of the contracting parties as to the governing law, and the principal place of business of
relevant entities.
After scrutinizing the case records, the Supreme Court concluded that Kenya had the most significant
relationship to the conflict, thereby necessitating the application of Kenyan law. The Supreme Court highlighted
that while the parties involved in the case were Filipinos, Kenya Air, the entity involved in the tortuous act and
the indemnity payment, is a foreign corporation with its principal place of business in Kenya.
Notably, the Release and Receipt executed by Esther explicitly stated that it shall be subject to the laws
of Kenya, underscoring the intention of the contracting parties to be bound by Kenyan law. Consequently, the
Supreme Court held that there was no legal basis to apply Philippine law to the matter and upheld the
application of Kenyan law.
The Supreme Court ruled in favor of Esther, granting the Petition for Review on Certiorari and setting
aside the decision of the Court of Appeals. #
SOLIS-MANLANGIT, MYTHEL FAITH T.
Conflict of Laws
A compilation of Case Digests
____________________________________________________________________________________________________________

CASE NO. 2
RAYTHEON INTERNATIONAL. INC. VS STOCKTON W. ROUZIE, JR.
GR NO. 162894 FEBRUARY 26, 2008

FACTS:

ISSUE:

RULING:
SOLIS-MANLANGIT, MYTHEL FAITH T.
Conflict of Laws
A compilation of Case Digests
____________________________________________________________________________________________________________

CASE NO. 3
MORA ADONG vs. CHEONG SENG GEE
G.R. No. 18081 March 3, 1922

FACTS:
The case concerns the intestate estate of Cheong Boo, a Chinese national who passed away in
Zamboanga, Philippine Islands, on August 5, 1919. The estate, valued at nearly P100,000, became a matter of
contention between two claimants asserting familial ties to the deceased.

On one side, Cheong Seng Gee asserted his status as the legitimate son of Cheong Boo, purportedly
born from a marriage contracted with Tan Dit in China in 1895. Conversely, Mora Adong claimed to have
entered into a valid marriage with Cheong Boo in 1896, according to Mohammedan rites in Basilan, Philippine
Islands. Two surviving daughters, Payang and Rosalia, were born from this union.

The conflicting claims were adjudicated before the Court of First Instance of Zamboanga. Upon review of
the evidence, the trial judge determined that the proof presented did not sufficiently establish the existence of
Cheong Seng Gee's alleged Chinese marriage. However, recognizing Cheong Seng Gee's admission to the
Philippine Islands as the son of the deceased, the court acknowledged him as a natural child.

In contrast, the court found the evidence supporting the Mohammedan marriage between Mora Adong
and Cheong Boo to be adequate. Despite its irregularity under Philippine law, the court recognized Payang and
Rosalia as legitimate daughters of Cheong Boo and Mora Adong.

Both parties appealed the trial court's decision. Upon appellate review, the Supreme Court affirmed the
trial court's ruling regarding the lack of sufficient evidence for the Chinese marriage. Consequently, Cheong
Seng Gee was upheld as a natural child. However, the Mohammedan marriage was deemed valid, entitling
Mora Adong and her daughters to their rightful inheritance under applicable law.

ISSUES:
1. Whether or not the Chinese marriage, mainly proven by an alleged matrimonial letter, is valid in the
Philippines.
2. Whether or not marriages performed in the Philippines according to the rites of the Mohammedan religion
are valid.

RULING:
1. No. The Court ruled that the alleged Chinese marriage was not validly proven due to a lack of competent
testimony on the laws of China concerning marriage in 1895 and insufficient evidence to establish its
existence. This ruling aligns with the Comity Principle, which dictates that marriages contracted outside
the Philippines are recognized as valid within the country if they adhere to the laws of the jurisdiction
where the marriage took place. Additionally, under Philippine law, marriages must be proven by
competent evidence, and failure to provide such evidence renders the marriage invalid.
2. Yes. The Court affirmed the validity of the Mohammedan marriage, citing section IX of the Marriage Law
(General Order No. 68), which recognizes marriages solemnized with belief in the authority of the
officiating person as lawful. This ruling is in accordance with the Curative Provision of Section IX, General
Order No. 68, which states that marriages solemnized with the belief in their lawfulness shall not be
invalidated due to lack of authority or formal defects. Moreover, the Philippine legal system recognizes
the freedom of religion and respects marriages solemnized according to religious customs, including
those of the Mohammedan religion, provided they do not contravene public policy or other legal
requirements. #
SOLIS-MANLANGIT, MYTHEL FAITH T.
Conflict of Laws
A compilation of Case Digests
____________________________________________________________________________________________________________

CASE NO. 4
REPUBLIC OF THE PHILIPPINES vs. CIPRIANO ORBECIDO III
G.R. No. 154380 October 5, 2005

FACTS:
Cipriano Orbecido III married Lady Myros M. Villanueva on May 24, 1981, at the United Church of Christ
in the Philippines in Lam-an, Ozamis City. Their union produced two children, Kristoffer Simbortriz V. Orbecido
and Lady Kimberly V. Orbecido. In 1986, Lady Myros left for the United States, taking their son Kristoffer with
her. Several years later, Cipriano discovered that Lady Myros had become a naturalized American citizen and
had obtained a divorce decree, subsequently marrying a man named Innocent Stanley.

In 2000, upon learning of Lady Myros's divorce and subsequent remarriage, Cipriano filed a petition with
the trial court seeking authority to remarry. He invoked Paragraph 2 of Article 26 of the Family Code, which
provides that if a marriage between a Filipino citizen and a foreigner is validly celebrated and the foreign spouse
obtains a divorce abroad, the Filipino spouse is allowed to remarry under Philippine law.

The trial court granted Cipriano's petition, allowing him to remarry. However, the Republic, represented by
the Office of the Solicitor General (OSG), sought reconsideration of the decision. The OSG argued that
Paragraph 2 of Article 26 of the Family Code only applies to valid mixed marriages between a Filipino citizen
and an alien, and that Cipriano's marriage did not qualify as such. Additionally, the OSG contended that there
was no specific law governing Cipriano's situation, and that his proper remedy should be to file a petition for
annulment or legal separation.

ISSUE:
Whether or not a divorce decree obtained by a Filipino citizen later naturalized as a foreign citizen
capacitates the other Filipino spouse to remarry

RULING:
Yes. The court interpreted Paragraph 2 of Article 26 of the Family Code to encompass situations where
one party, initially a Filipino citizen at the time of marriage, later becomes naturalized as a foreign citizen and
secures a divorce decree abroad. This interpretation serves to prevent unjust outcomes where a Filipino spouse
remains bound in marriage to an alien spouse who has obtained a foreign divorce. Emphasizing the legislative
intent behind the provision, the court applied a rule of reason, ensuring that the law serves its intended purpose
effectively.

However, the court underscored the importance of substantiating such claims with adequate evidence. In
the absence of compelling evidence presented by the respondent regarding the divorce decree and
naturalization of his wife, the court could not conclusively affirm his capacity to remarry. Consequently, the
petition by the Republic was granted, highlighting the necessity for due diligence in presenting evidence to
support claims under Paragraph 2 of Article 26.
SOLIS-MANLANGIT, MYTHEL FAITH T.
Conflict of Laws
A compilation of Case Digests
____________________________________________________________________________________________________________

CASE NO. 5
MARIA REBECCA MAKAPUGAY BAYOT vs. THE HONORABLE COURT OF APPEALS and VICENTE
MADRIGAL BAYOT
G.R. No. 155635 November 7, 2008

FACTS:
Vicente and Rebecca exchanged vows on April 20, 1979, at Sanctuario de San Jose, Greenhills,
Mandaluyong City. Rebecca, indicated as 26 years old on the Marriage Certificate, was listed as an American
citizen born in Agaña, Guam, USA, to Cesar Tanchiong Makapugay and Helen Corn Makapugay, both American
nationals. Their union bore fruit with the birth of Marie Josephine Alexandra, fondly known as Alix, on November
27, 1982, in San Francisco, California.

As time passed, strains appeared in Vicente and Rebecca's marital relationship, leading Rebecca to
initiate divorce proceedings in the Dominican Republic in 1996. The Dominican court issued Civil Decree No.
362/96 on February 22, 1996, dissolving their marriage and allowing them to remarry upon fulfilling legal
requirements. Subsequently, Civil Decree No. 406/97 addressed their property matters per their December 14,
1996 agreement.

Shortly after the issuance of Civil Decree No. 362/96, Rebecca filed a petition for the declaration of nullity
of marriage with the Makati City RTC. However, she later withdrew the petition. In May 1996, Rebecca executed
an Affidavit of Acknowledgment, asserting her American citizenship and disclosing her separation from Vicente
since 1993, along with the impending birth of a child not fathered by Vicente.

On March 21, 2001, Rebecca filed another petition with the Muntinlupa City RTC, seeking the declaration
of absolute nullity of marriage due to Vicente's purported psychological incapacity. She also sought the
dissolution of the conjugal partnership, support pendente lite for herself and Alix, and a monthly support of
PhP220,000 for Alix. Vicente, meanwhile, filed a Motion to Dismiss citing lack of cause of action and the divorce
judgment's preclusive effect. Simultaneously, both parties lodged criminal complaints against each other, with
Vicente filing adultery and perjury charges against Rebecca, while Rebecca accused Vicente of bigamy and
concubinage.

The RTC denied Vicente's motion to dismiss and granted Rebecca's plea for support pendente lite.
Vicente sought relief from the Court of Appeals through a petition for certiorari. The CA granted a temporary
restraining order (TRO) and, by its Decision dated March 25, 2004, effectively dismissed Civil Case No. 01-094,
along with ancillary orders issued by the RTC.

ISSUE:
Whether or not the divorce decree obtained in the Dominican Republic can be validly recognized in the
Philippines

RULING:
Yes. The court affirms the validity of the Divorce Doctrine. Rebecca, at the time she sought and obtained
her divorce, was unequivocally an American citizen, a status she maintained and continues to hold, having been
born to American parents in Guam, an American territory that grants citizenship through jus soli. Her American
citizenship is further evidenced by her marriage certificate, Alix's birth certificate, and the documents pertaining
to her divorce proceedings in the Dominican Republic. As an American citizen, Rebecca was subject to the laws
of the United States, a country that permits divorce.

The Dominican Republic court, appropriately addressed the former couple's property matters in
accordance with Dominican law. To recognize a foreign divorce in our jurisdiction, it must be demonstrated as a
fact and validated under the national law of the alien spouse. Given Rebecca's undeniable American citizenship
at the time of divorce and the recognition of divorce in any U.S. state, the presentation of a duly authenticated
copy of the foreign divorce decree suffices for recognition.
SOLIS-MANLANGIT, MYTHEL FAITH T.
Conflict of Laws
A compilation of Case Digests
____________________________________________________________________________________________________________

Therefore, the foreign decrees issued by the Dominican Republic court are deemed valid and binding on
both Rebecca and Vicente.