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Suzuki v. Office of the Solicitor General

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Suzuki v. Office of the Solicitor General

Case Title and Citation

Karl William Yuta Magno Suzuki a.k.a. Yuta Hayashi, petitioner, vs. Office of the Solicitor General, respondent.
G.R. No. 212302, September 02, 2020
Supreme Court - Second Division
Ponente: Justice Perlas-Bernabe

Facts

  • Petitioner Karl William Yuta Magno Suzuki, born April 4, 1988 in Manila, is the child of Sadao Kumai Suzuki (Japanese national) and Lorlie Lopez Magno (Filipino). Their marriage occurred on December 29, 1987.
  • Identification Certificate No. 08-19540 (issued by the Bureau of Immigration on March 31, 2008) lists petitioner as a Filipino citizen.
  • Petitioner’s parents divorced on June 12, 1997.
  • On December 6, 2002, Lorlie Magno married Japanese national Hikaru Hayashi in San Juan City, Metro Manila.
  • On November 9, 2004, at age 16, petitioner was adopted by Hayashi under Japanese law; this adoption was reflected in Hayashi’s Koseki (Family Register).
  • The Koseki and its English translation were authenticated at the Philippine Consulate General on May 15, 2007.
  • At age 24, petitioner sought recognition of his Japanese-law adoption by Hayashi in the Philippines.
  • On May 24, 2013, petitioner filed a Petition for Judicial Recognition of Foreign Adoption Decree before the RTC of Marikina City.
  • On June 4, 2013, the RTC required the Office of the Solicitor General (OSG) to file a comment.
  • In its Comment/Opposition dated November 4, 2013, the OSG argued that Philippine law strongly regulates adoptions by aliens and that inter-country adoption is governed by RA 8043 (Inter-Country Adoption Act of 1995) and RA 8552 (Domestic Adoption Act of 1998). It contended that petitioner’s adoption did not comply with these statutes and should not be recognized.
  • On November 21, 2013, the RTC dismissed the petition as “contrary to law and public policy.”
  • Petitioner filed a Motion for Reconsideration, which the RTC denied on April 23, 2014, reaffirming that RA 8043 and RA 8552 govern adoptions of Filipino citizens and that the petition lacked a judgment or final order of a foreign tribunal.
  • Petitioner then sought review directly before the Court on pure questions of law.
  • In 2017, the Court required memoranda; petitioner relied on guidelines on foreign-judgment registration and various OCRG rules; the OSG reiterated that the petition concerns adoptions under Philippine law and that foreign adoptions are not automatically recognized.
  • The Court held that recognition of foreign judgments relating to the status of a person is generally permissible under Section 48, Rule 39 of the Rules of Court, and that foreign adoptions of a Filipino citizen, if proven, may be judicially recognized.
  • The Court remanded the case to the RTC for further proceedings consistent with the Decision, noting that recognition of a foreign judgment is a fact-based inquiry and may be proven by official publication or certification of the foreign judgment, authenticated by consular or diplomatic channels if necessary.
  • The RTC was instructed to reinstate the petition for further proceedings to determine whether the Japanese adoption decree, if proven, may have effect in the Philippines.

Issues

  1. Is a foreign judgment of adoption involving a Filipino citizen subject to judicial recognition in the Philippines under Section 48, Rule 39 of the Rules of Court?
  2. Do RA 8043 (Inter-Country Adoption Act) and RA 8552 (Domestic Adoption Act) preclude recognition of a foreign adoption decree in this context?
  3. If a foreign judgment of adoption is proven and not contrary to public policy, may Philippine courts recognize and give it effect despite Philippine adoption laws?

Ruling

  1. Yes — A foreign judgment of adoption involving a Filipino citizen may be judicially recognized under Section 48, Rule 39 of the Rules of Court, provided it is proven and not contrary to public policy.
  2. No — RA 8043 and RA 8552 do not automatically preclude recognition of a foreign adoption decree; recognition may proceed where the foreign adoption is permitted by law and not in conflict with Philippine public policy or status rules, and where applicable, the foreign decree may be recognized notwithstanding the acts’ general regulatory framework.
  3. Yes — If proven as a fact and not contrary to public policy, the foreign judgment may be recognized and its effects reflected in the Philippine civil registry, subject to the standard grounds for repelling foreign judgments (e.g., lack of jurisdiction, notice, collusion, fraud, or clear mistake of law or fact).

Reasoning / Ratio Decidendi

  • Adoption creates a status akin to legitimate paternity and filiation; Philippine law recognizes the regulation of adoption but may grant recognition to foreign decrees that determine the status between a party and a child when foreign judgments involve a Filipino party.
  • Article 15 of the Civil Code binds Philippine law on family rights and the status of persons, including when the foreign judgment concerns a Filipino citizen living abroad; Philippine courts must consider the foreign judgment’s effect on the Filipino party while recognizing that the foreign court’s determination as to the adopter’s rights/obligations is limited by the foreign court’s jurisdiction and the parties’ rights.
  • Section 48, Rule 39 of the Rules of Court governs the effect of foreign judgments: a judgment against a person is presumptive evidence of a right and may be conclusive upon proof, unless there is extrinsic ground to repel it (lack of jurisdiction, notice, collusion, fraud, or clear mistake of law or fact).
  • In Fujiki v. Marinay, the Court explained that a copy of a foreign judgment may be admitted in evidence and proven as a fact under Rule 132, Sections 24 and 25, in relation to Rule 39, Section 48(b). A certified copy or a publication by the foreign court or a consular-documented copy may suffice.
  • The recognition-and-enforcement framework is rooted in generally accepted principles of international law and the Constitution’s incorporation clause; recognition is not substitution of the foreign court’s decision but an extension of its effects to the Philippine context, particularly for status determinations affecting Philippine registries.
  • RA 8043 governs inter-country adoptions of Filipino children; its applicability to Hayashi, a Japanese adopter, is limited by Article 184(3)(b) of the Family Code, which permits aliens to adopt the legitimate child of a Filipino spouse, subject to specific conditions; the majority ruling found that such provisions do not automatically bar recognition of a foreign decree if the foreign adoption complies with the law and is proven to exist, and if recognition would not contravene Philippine public policy.

Doctrine / Legal Principle

  • Recognition of foreign judgments is permissible under Section 48, Rule 39 of the Rules of Court, rooted in generally accepted international-law principles (opinio juris) and constitutional incorporation.
  • In status-related foreign judgments (such as adoption), Philippine courts determine whether to extend the foreign judgment’s effects to a Filipino party, rather than reassessing the foreign court’s decision.
  • Article 15 of the Civil Code binds laws on family rights and status of persons, including Philippine laws’ reach over citizens abroad; however, foreign judgments may still be recognized for the adoptee’s status when properly proven.
  • Inter-country adoption statutes (RA 8043) apply to Filipino children; aliens may adopt under specific circumstances (RA 8552), but these laws do not automatically preclude recognition of a foreign adoption decree if the decree is proven and not contrary to public policy.
  • To implement recognition, the foreign decree may be proven by official publication, a certified copy, or a consular-documented copy authenticated by the proper authorities.

Disposition

  • The petition is GRANTED. The November 21, 2013 and April 23, 2014 RTC orders in JDRC Case No. 2013-2279-MK are REVERSED and SET ASIDE. The RTC is ORDERED to reinstate the petition for further proceedings to recognize the foreign adoption decree consistent with this Decision.
  • The recognition of the foreign judgment, if proven, will be reflected in the Philippine civil registry.

Concurring / Dissenting Opinions

  • Justices Perlas-Bernabe, Hernando, and Delos Santos concur in the Decision.
  • Justice Baltazar-Padilla participated on leave.
  • No separate dissenting opinion is stated in the provided material.

Significance / Notes

  • Clarifies that foreign adoption decrees involving Filipino citizens may be judicially recognized in the Philippines, subject to proof and public-policy constraints.
  • Balances Philippine adoption law with international comity by allowing recognition of foreign judgments when appropriate.
  • Emphasizes that recognition is not automatic; the foreign judgment must be proven in accordance with Rules of Court and may be challenged on extrinsic grounds.
  • Illustrates interplay between RA 8043, RA 8552, and the recognition of foreign judgments within domestic registry procedures.
  • Encourages reconciliation between domestic adoption rules and recognition of foreign decrees to promote child welfare and transnational family ties.
Judicial Recognition of Foreign Judgments Inter-Country Adoption Family Code Inter-Country Adoption Act (RA 8043) Domestic Adoption Act (RA 8552) Rules of Court
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