Question

A married couple, Juan and Maria, got divorced in the Philippines. As part of the divorce settlement, Maria was granted custody of their child. After the divorce, Maria decides to move to the United States with the child to start a new life. However, Juan disagrees with this decision and believes that Maria is violating his parental rights. He wants to contest the custody arrangement and seek the return of the child to the Philippines.

According to the Civil Code of the Philippines, specifically Articles 15-18 on Conflict of Laws, discuss the applicable rules and principles for the recognition and enforcement of foreign judgments regarding custody rights. What legal remedies are available to Juan to challenge the custody arrangement made by Maria in the United States? Explain the requirements and procedures for the recognition and enforcement of foreign judgments related to child custody. Consider any relevant international conventions or treaties that may apply.