197 SCRA 863 Civil Law Preliminary Title Conflict of Laws Foreign Laws; How

Proven Proof of Foreign Laws Processual Presumption

On July 6, 1960, Santiago Gatchalian, grandfather of William Gatchalian, was recognized
by the BOI as a native born Filipino citizen. Santiago Gatchalian testified that he has 5
children.
On June 27, 1961, William Gatchalian then a twelve year old minor arrived in Manila and
sought admission as Filipino citizen which was eventually granted by the board of special
inquiry. However, the Secretary of Justice issued a memorandum setting aside all decisions
and directed the Board of Commissions to review all cases where entry was allowed among
which was that of William Gatchalian.
ISSUE: Whether or not the marriage of Gatchalian in China is valid in accordance with
Philippine law.
HELD: Yes. The Supreme Court held that in the absence of the evidence to the contrary
foreign laws on a particular subject are presumed to be the same as those of the
Philippines. This is known as Processual Presumption. In this case, there being no proof of
Chinese law relating to marriage, there arises a presumption that it is the same of that of
Philippine law the said marriage then is declared valid. Therefore, William Gatchalian
following the citizenship of his father is a Filipino citizen.