All ▸ Bar 2024 ▸ CIVIL LAW ▸ I. EFFECT AND APPLICATION OF LAWS ▸ M. Conflict of Laws (Civil Code, arts. 15-18) ▸ 3. Recognition and Enforcement of Foreign Judgment

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Conflict of Laws: Recognition and Enforcement of Foreign Judgments

Mr. Santos, a Filipino citizen, filed a civil case against Mr. Johnson, a foreign national, in a Philippine court. The Philippine court rendered a judgment in favor of Mr. Santos. However, Mr. Johnson, who resides in the United States, refuses to comply with the Philippine court's decision.

Under the provisions of the Civil Code (Articles 15-18) on Conflict of Laws, discuss the following:

What are the conditions for the recognition and enforcement of foreign judgments in the Philippines?
Can Mr. Santos seek the recognition and enforcement of the Philippine court's judgment in the United States? What legal principles govern this matter?
What remedies are available to Mr. Santos in order to enforce the Philippine court's judgment against Mr. Johnson in the Philippines?

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