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THIRD DIVISION.
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rules of evidence" [Article 12, Civil Code.] On this score the Court
had occasion to state that "a local custom as a source of right
cannot be considered by a court of justice unless such custom is
properly established by competent evidence like any other fact"
[Patriarca v. Orate, 7 Phil. 390, 395 (1907).] The same evidence, if
not one of a higher degree, should be required of a foreign custom.
Same; Same; Marriages; To establish a valid foreign
marriage, the existence of the foreign law as a question of fact and
the alleged foreign marriage by convincing evidence must be
proven.Construing this provision of law the Court has held that
to establish a valid foreign marriage two things must be proven,
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