Question

Rosa, a resident of the Philippines, obtained a monetary judgment against Juan, a resident of Spain, in a court in the Philippines. The judgment was based on a breach of contract between Rosa and Juan. After obtaining the judgment, Rosa learned that Juan owns property in Spain. She wants to enforce the Philippine judgment in Spain to recover the awarded amount. However, Juan refuses to comply with the judgment and argues that it cannot be enforced in Spain.

In this scenario, discuss the following:

1. What are the principles under Article 15 of the Civil Code that govern the recognition and enforcement of foreign judgments? Explain each principle briefly.
2. Can Rosa compel Juan to comply with the Philippine judgment in Spain? Discuss the conditions and limitations under Article 17 of the Civil Code for the recognition and enforcement of a foreign judgment.
3. What are the procedures and requirements for the enforcement of a foreign judgment in the Philippines? Discuss the provisions under Article 18 of the Civil Code.