However, she said this foreign judgment
must be passed upon judicially by a Philippine Court to prove its validity.
Airways argues that Wisconsin can't levy against its assets in Arkansas without first obtaining a legal ruling and then registering a foreign judgment
The principle could also involve 'state assets' and the waiver of sovereign immunity from 'execution, with the related aspect of automatic recognition of the foreign judgment
or arbitral award.'
Full Faith and Credit Clause, the recognition of a foreign judgment
Section 13 of the Civil Code of India provides the criteria for recognition of a foreign judgment
and is a pre-condition to any enforcement proceedings under Section 44A of the code.
"Whether a foreign judgment
is enforceable in New Zealand will be governed by the laws of New Zealand and is a question for the Courts of New Zealand to determine."
Meanwhile, even if a foreign judgment
opening a bankruptcy proceeding meets all the statutory requirements under article 5 of EBL 2006, the judgment might still fail the implicit jurisdictional requirement.
With the theme, 'The Philippines and the Dynamics of International Law in a Time of Transition,' the conference examined issues in a number of discussion panels ranging from human rights, territorial disputes, regional maritime security, international trade law, as well as armed conflict and terrorism, to environmental law and sustainable development, Asean law, enforcement of foreign judgment
and Philippine reception of international law.
Conversely, then, reasons for not recognizing a foreign judgment
At the same time, the CA said that "for Philippine courts to recognize a foreign judgment
relating to the status of a marriage where one of the parties is a citizen of a foreign country, the petitioner only needs to prove said foreign judgment
as a fact under the Rules of Court."
LLC v Ben Ashbury declaration of foreign judgment
, $13,950 CSC
circumstances in which a registered foreign judgment
must be set aside