People v Padica

April 7, 1993 | Crimes Against Persons | Joses Tan

Recit-ready Summary:
A class action suit was judged upon the US District Court, District of
Hawaii, against the Marcos Estate for human rights violations such as
arbitrary detention, torture and rape in the hands of police or military forces
during the Marcos regime. The US District Court rendered a Final
Judgment awarding plaintiff class around $1.96 million
($1,964,005,859.90). Final Judgment was eventually affirmed by the US
Court of Appeals for the Ninth Circuit.
The Marcos Estate argued that the petitioners failed to pay the correct
filing fees of 472 million pesos. However, generally accepted principles of
international law, by virtue of the incorporation clause of the Constitution,
form part of the laws of the land even if they do not derive from treaty
obligations. Hence, the decision of the US District Court should be
recognized and enforced in this case.

Relevant Issue/s: W/N the decision of the US District Court should be

recognized and enforced in the Philippines? YES.

Holding: Although there is no explicit obligatory rule that requires the

Philippines to recognize and enforce foreign judgments, this is still valid
based on the generally accepted principles of international law. Due to the
incorporation clause of the Constitution, the Philippines is subjected to
comply with such foreign judgments. Furthermore, Section 48, Rule 39
acknowledges that the actionable issues are generally restricted to a review
of jurisdiction of the foreign court, the service of personal notice, collusion,
fraud or mistake of fact or law.

Doctrine: NO OBLIGATORY RULE AND GENERAL PRINCIPLES OF

LAW - There is no obligatory rule derived from treaties or conventions that
requires the Philippines to recognize foreign judgments or allow a
procedure for the enforcement thereof. However, generally accepted
principles of international law, by virtue of the incorporation clause of the
Constitution, form part of the laws of the land even if they do not derive
from treaty obligations.