Maria Teresa Dino Basa-Egami v. Dr. Lisa Grace Bersales

Summary

This landmark Supreme Court case addressed the recognition of consensual foreign divorces under Article 26(2) of the Family Code. Maria Teresa Basa-Egami, a Filipino married to Japanese national Hiroshi Egami, sought recognition of their 2008 Japanese divorce decree to remarry. The RTC initially granted the petition, but the Court of Appeals reversed for insufficient proof of Japanese law. The Supreme Court, despite the procedural defect of filing certiorari instead of appeal, ruled on the merits to serve substantial justice. Following the Manalo doctrine, the Court held that consensual divorces abroad may be recognized regardless of who initiated them, rejecting the restrictive interpretation that only adversarial divorces qualify. However, while the Court found sufficient evidence of the divorce fact, it sustained the finding of inadequate proof of Japanese divorce law. The case was remanded for additional evidence, highlighting the continuing challenge Filipino spouses face in proving foreign law requirements for divorce recognition.