Question

Maria and Juan, both Philippine nationals, decided to get married in Australia. They went through the necessary legal processes and obtained a marriage license in Australia. However, upon their return to the Philippines, they encountered difficulty in having their marriage recognized by the Philippine government. The Department of Foreign Affairs argued that the marriage should not be recognized since it did not comply with the formal requirements of the Family Code of the Philippines.

Considering the concept of lex loci celebrationis, which refers to the law of the place where a marriage is celebrated, analyze the following scenarios:

1. If Maria and Juan's marriage is recognized as valid in Australia, should it also be considered valid in the Philippines, even if it did not comply with the formal requirements of the Family Code of the Philippines?
2. What if there is a conflict of laws between Australia and the Philippines regarding the formal requirements for marriage? How would the doctrine of renvoi come into play?
3. Under the doctrine of processual presumption, what factors would the Philippine courts consider in determining the validity of the marriage between Maria and Juan?