As held in Garcia
v. Recio,
418 Phil. 723, 723-735 (2001), divorce obtained
abroad is proven by the divorce decree itself. Indeed the best evidence of a judgment is the judgment itself. The
decree purports to be a written act or record of an act of an official body or
tribunal of a foreign country. x x x
x It is well-settled in our
jurisdiction that our courts cannot take
judicial notice of foreign laws. Like any other facts, they must be alleged
and proved. Australian marital laws are not among those matters that judges are
supposed to know by reason of their judicial function. The power of judicial
notice must be exercised with caution, and every reasonable doubt upon the
subject should be resolved in the negative (MEROPE ENRIQUEZ VDA. DE CATALAN VS. LOUELLA A. CATALAN-LEE, G. R. NO. 183622,
FEBRUARY 8, 2012, SERENO, J.).
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