VDA. DE CATALAN v. CATALAN-LEE G. R. No. 183622, February 08, 2012

Under the principles of comity, Philippine jurisdiction recognizes a valid divorce obtained by a spouse of foreign nationality. Aliens may obtain divorces abroad, which may be recognized in the Philippines, provided they are valid according to their national law. Nonetheless, the fact of divorce must still first be proven by the divorce decree itself.

The best evidence of a judgment is the judgment itself. 

Under Sections 24 and 25 of Rule 132, 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.