RULINGS OF DIFFERENT CASES
15 SCRA 355 (1965)
Tenchavez vs. Escano
Ruling:
For the Philippine courts to recognize
and give recognition or effect to a
foreign decree of absolute divorce
between Filipino citizens would be a
patent violation of the declared public
policy of the state, especially in view
of the third paragraph of Article 17 of
the Civil Code that prescribes the
following:
‘Prohibitive laws cornering
persons, their acts or property, and
those which have for their object
public order, policy and good customs,
shall not be rendered ineffective by
laws or judgments promulgated, or by
determinations or conventions agreed
upon in a foreign country.’
174 SCRA 653 (1989)
Pilapil vs. Ibay-Somera
Ruling:
The Supreme Court ruled that since
Erich was no longer the husband of
Pilapil, he no longer had the legal
standing to sue for adultery. Under
Article 344 of the Revised Penal Code,
the crime of adultery, as well as other
crimes against chastity, can be
prosecuted only upon the complaint of
the offended spouse.
G.R. No. L-16749 (January 31, 1963)
Edward Christensen vs Helen
Christensen
Ruling:
Since the conflicts rule of California
refers back the matter to the
Philippines (the place of domicile), our
courts have no alternative but to accept
the referring back to us. If our courts
will to do otherwise and throw back the
matter to California, the problem
would be tossed back and forth
between states concerned, resulting in
“international football.”
Renvoi Doctrine
G.R. No. L-5426 (May 29, 1953)
Ramon Joaquin vs. Antonio
Navarro
Ruling:
Rule 123, Section 69, Revised Rules of
Court: When two persons perish in the
same calamity, such as wreck, battle or
conflagration, and it is not (a) shown
who died first and there are no (b)
particular circumstances from which it
can be inferred, the survivorship is
presumed from the probabilities
resulting from the strength and age of
the sexes
G.R. No. L-68470 (October 8, 1985)
Alice Reyes Van Dorn vs. Hon.
Manuel V. Romillo, Jr.
Ruling:
It is true that owing to the nationality
principle embodied in Article 15 of the
Civil Code, only Philippine nationals
are covered by the policy against
absolute divorces the same being
 RULINGS OF DIFFERENT CASES

considered contrary to our concept of

public police and morality. However,
aliens may obtain divorces abroad,
which may be recognized in the
Philippines, provided they are valid
according to their national law. In this
case, the divorce in Nevada released
private respondent from the marriage
from the standards of American law,
under which divorce dissolves the
marriage