WRITING OR DOCUMENT MAY BE PROVEN AS PUBLIC OR OFFICIAL RECORD OF A FOREIGN COUNTRTY:

     As held in Garcia vs. Recio, 418 Phil. 723, (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.  Under Sections 24 and 25 of Rule 132, on the other hand, a writing or document may be proven as a public or official record of a foreign country by either (1) an official publication or (2) a copy thereof attested by the officer having legal custody of the document. If the record is not kept in the Philippines, such copy must be (a) accompanied by a certificate issued by the proper diplomatic or consular officer in the Philippine foreign service stationed in the foreign country in which the record is kept and (b) authenticated by the seal of his office. (Merope Enriquez Vda. De Catalan vs. Louella A. Catalan-Lee, G. R. No. 183622, February 8, 2012, Sereno, J.).