Article 15:FELICITAS AMOR-CATALANVSCA & ORLANDO CATALAN& MEROPE BRAGANZAFACTS: Petitioner married respondenton 1950.

They migrated to the USA andallegedly beca meNATURALIZED CITIZENS.[April 1988] They divorced.[June 1988] RespondentOrlando married respondentMeropePetitioner filed a Declarationof Nullity of Marriage aga instrespondent Orlando andMerope contending that themarriage was bigamous sincer espondent Merope had aprior subsisting marriage withBristol.Respondents moved to dismiss on the ground of lackof cause of action aspetitioner is not a real party -in-interest. However, this wasdenied. ISSUE:[1] W/N PETITIONER &RESPONDENT ORLANDOHAD INDEED BECOMENATURALIZED AMERICA NCITIZEN[2] W/N THEY HADACTUALLY OBTAINED ADIVORCE DECREERULING: The records show that therewas no competent evidenceto prove their naturalizati onand divorce. Divorce means the legaldissolution of a lawful unionfor a cause arising aftermarriage.Bu t divorces are of differenttypes. The two basic ones are:(1) Absolute divorce or avinculo matrimonii -terminates the marriage(2) Limited divorce or amensa et th oro - suspends itand leaves the bond in fullforce.A divorce obtained abroad byan alien may be recognized inour jurisdiction, provided suchdecree is valid accord ing tothe national law of theforeigner.However, before it can berecognized by ou r courts, theparty pleading it must provethe divorce as a fact anddemonstrate it s conformity tothe foreign law allowing it,which must be provedconsidering that our courtscannot take judicial notice of foreign laws. Without the divorce decree and foreign law as part of the evidence, we cannot ruleon the issue of whetherpetitioner has the personalityto file the petition fordeclaration of nullity of marriage.After all , she may have thepersonality to file the petitionif the divorce decree obtained was a limited divorce or amensa et thoro; or the foreignlaw may restrict remarri ageeven after the divorce decreebecomes absolute.In such case, the RTC wouldbe c orrect to declare themarriage of the respondentsvoid for being bigamous,there be ing already inevidence two existingmarriage certificates, whichwere both obtaine d in thePhilippines:[1] In Mabini, Pangasinandated December 21, 1959between Euse bio Bristol andrespondent Merope[2] In Calasiao, Pangasinandated June 16, 1988 b etweenthe respondents.However, if there was indeeda divorce decree obtainedand w hich, following thenational law of Orlando, doesnot restrict remarriage, theCour t of Appeals would becorrect in ruling thatpetitioner has no legalpersonality to file a petition todeclare the nullity of marriage, thus:Freed from their existi ngmarital bond, each of theformer spouses no longer hasany interest nor should e achhave the personality toinquire into the marriage thatthe other might subseque ntlycontract.Viewed from anotherperspective, Felicitas has noexisting interest i n Orlando ssubsequent marriage sincethe validity, as well as anydefect or infirmity, of thissubsequent marriage will notaffect the divorced status of Orlando and Fe licitas.In fine, petitioner spersonality to file the petitionto declare the nullity of marriage cannot beascertained because of theabsence of:[1] Divorce decree[2] Foreign law allowing itHence, a remand of the caseto the trial court for receptionof additional evidence isnecessary to determinewhether respondent Orlandowas grant ed a divorce decreeand whether the foreign lawwhich granted the sameallows or re stricts remarriage.If it is proved that a validdivorce decree was obtainedand th e same did not allowrespondent Orlando sremarriage, then the trial