Van Dorn vs.

Romillo
GR No. 68470, October 8, 1985, 139 SCRA 140

Facts:
In 1972, Alice Van Dorn, a Filipino, was married to Richard Upton, a citizen of the United States. After
that, they established their residence in the Philippines and had two children. However, in 1982, Alice
and Richard were divorced in Nevada, United States. Alice had also remarried in Nevada to Theodore
Can Dorn.

In 1983, Upton filed a suit in order to transfer the management of their properties to him, which was
considered conjugal property. He contended that since divorce is not recognized in the Philippines, the
divorce decree cannot prevail over the prohibitive laws of the Philippines.

Issue:
Was the divorce obtained by Alice and Richard in Nevada valid in the Philippines?

Ruling:

Yes. Even though Article 15 states that Filipinos should be governed by Philippine laws in matters of
status even if they are living abroad, aliens may obtain divorces abroad, and those would be deemed
valid in the Philippines if valid in the country where it was executed.