Question

Conflict of Laws: Recognition and Enforcement of Foreign Judgment

In a recent case, John, a resident of the Philippines, entered into a contract with Sarah, a resident of Australia, for the sale and delivery of goods. However, a dispute arose between them regarding the terms of the contract, leading them to file separate lawsuits in their respective countries.

In the Philippines, the court rendered a judgment in favor of John, and awarded him damages. Meanwhile, in Australia, the court also rendered a judgment in favor of Sarah, ordering John to pay her damages.

Given these circumstances, discuss the following issues:

1. What is meant by recognition and enforcement of a foreign judgment?
2. Under Philippine law, how is the recognition and enforcement of a foreign judgment determined?
3. Can John enforce the Philippine judgment against Sarah in Australia? Why or why not?
4. If Sarah wants to enforce the Australian judgment against John in the Philippines, what legal requirements need to be met?