Van Dorn v. Romillo
G.R. No. L-68470
October 8, 1985
ALICE REYES VAN DORN, petitioner,
vs.
HON. MANUEL V. ROMILLO, JR., as Presiding Judge of Branch CX, Regional Trial Court of the National Capital Region Pasay City and RICHARD UPTON respondents
Facts:
In 1972, Alice Van Dorn, a Filipino, was married to Richard Upton, a citizen of the United States. After that, they established their residence in the Philippines and had two children. However, in 1982, Alice and Richard were divorced in Nevada, United States. Alice had also remarried in Nevada to Theodore Can Dorn.
In 1983, Upton filed a suit in order to transfer the management of their properties to him, which was considered conjugal property. He contended that since divorce is not recognized in the Philippines, the divorce decree cannot prevail over the prohibitive laws of the Philippines.
Issue:
Was the divorce obtained by Alice and Richard in Nevada valid in the Philippines?
Ruling:
Yes. Even though Article 15 states that Filipinos should be governed by Philippine laws in matters of status even if they are living abroad, aliens may obtain divorces abroad, and those would be deemed valid in the Philippines if valid in the country where it was executed.
It's a Ping Thing 