Mijares v Ranada

GR No: 139325; Apr 12, 2005

FACTS: Petitioners were victims of human rights violations during the Marcos era. A final
judgement was held in their favor abasing the estate of the late President Ferdinand Marcos.
The US court awarded $1.9 billion as compensation for the torte it had during the said era. The
said judgement was affirmed by the US Court of Appeals. For the enforcement, petitioners filed
a complaint in RTC Makati and paid filing fees of Php 410 since the value of the subject matter
is incapable of pecuniary estimation. The heirs of Marcos filed a motion to dismiss because of
the said filing fees paid by the petitioners. The Makati RTC dismissed the case because the
subject matter was capable of pecuniary estimation since it involved a judgement from a foreign
court. Thus, it can be ascertained because it is a payment of definite sum even if it is in a
foreign currency. The proper filing fee should be Php 472 Million to enforce a judgement
awarded to them by the foreign court.

ISSUE: Can a foreign judgement be recognized in the Philippines?

RULING: YES. There is no obligatory rule regarding treaties entered into by the Philippines to
recognize foreign judgements or enforcement thereof. Exception to the rule is when it is a
generally accepted principle of international law, where the Philippines adhere through the
incorporation clause provided in the constitution even if there are no treaty obligations. A
generally accepted principle of international law must comply with the following requisites:
established, widespread and consistent practice on part of the states and a psychological
element known as opinio juris side necessitates or belief that the practice is considered
obligatory by the existence of a rule of law.