Chmielewski v. People

Summary

The Supreme Court denied petitioners' challenge to the denial of their motion to quash warrant of arrest in criminal proceedings. The case involved Polish national Jacek Chmielewski and his wife who sought to quash an arrest warrant, raising the validity of a foreign divorce decree as a relevant issue. The Court clarified that while Article 26 of the Family Code doesn't apply to foreign nationals, the validity of foreign divorce decrees under the alien's national law must still be proven in Philippine courts. Since courts don't take judicial notice of foreign laws, both the divorce decree and the applicable foreign law must be alleged and proven as facts, making these matters appropriate for resolution in a full trial rather than preliminary proceedings.