1. Why is an implied repeal of laws not favored? Explain.

Implied Repeal is not favorable since repeal by implication proceeds on the premise that where a
statute of later date clearly reveals an intention on the part of the legislature to abrogate a prior act
on the subject, that intention must be given effect. Hence, before there can be a repeal, there must
be a clear showing on the part of the lawmaker that the intent in enacting the new law was to
abrogate the old one. The intention to repeal must be clear and manifest; otherwise, at least, as a
general rule, the later act is to be construed as a continuation of, and not a substitute for, the first
act and will continue so far as the two acts are the same from the time of the first enactment.
(MECANO vs COMMISSION ON AUDIT, Gr. 103982, December 11, 1992, Campos Jr,J)

Thus when,

2. Can a divorce decree obtained abroad be given res judicata effect in this jurisdiction?
Explain In the case OSCAR P. MALLION vs EDITHA ALCANTARA, Res judicata is defined as "a
matter adjudged; a thing judicially acted upon or decided; a thing or matter settled by judgment.
It also refers to the rule that a final judgment or decree on the merits by a court of competent
jurisdiction is conclusive of the rights of the parties or their privies in all later suits on points and
matters determined in the former suit. The supreme court has elaborated where the following 4
essential conditions to apply res judicata in the case of CARMEN ALEDRO-RUÑA, v. LEAD EXPORT
AND AGRO-DEVELOPMENT concur, viz.: (1) there must be a final judgment or order; (2) the
court rendering it must have jurisdiction over the subject matter and the parties; (3) it must be a
judgment or order on the merits; and (4) there must be, between the two cases, identity of
parties, subject matter and causes of action.

When these elements are present, Given the validity and efficacy of divorce secured by a person
in a foreign country, the same shall be given a res judicata effect in this jurisdiction.