Hilaria Sikat v. John Canson

Summary

This case involved the validity of a foreign divorce decree and liquidation of conjugal partnership. Hilaria Sikat sought to liquidate marital property based on her husband John Canson's 1929 Nevada divorce decree obtained on grounds of desertion. The Supreme Court affirmed the lower court's dismissal, ruling that the Nevada divorce was invalid in the Philippines because: (1) the Nevada court lacked jurisdiction over the wife who remained domiciled in the Philippines, (2) desertion is not a valid ground for divorce under Philippine law (Act No. 2710), which only recognizes adultery by wife or concubinage by husband, and (3) foreign divorce decrees violate public policy under Civil Code Articles 9 and 11. The Court also noted that plaintiff had previously challenged the divorce's validity in a support action, creating inconsistent legal positions.