I got this from another website, and we're totally confused.
Why is the Judicial Recognition of Foreign Divorce not a requirement as to the foreigner spouse?
Since the Philippines follow the Nationality Principle, the State accords respect to the national laws of the foreign spouse with respect to the validity of the divorce decree.
"The decree is binding on private respondent as an American citizen...aliens may obtain divorces abroad, which may be recognized in the Philippines, provided they are valid according to their national law. In this case, the divorce in Nevada released private respondent from the marriage. Thus, pursuant to his national law, Private Respondent is no longer the husband of petitioner." (Van Dorn vs. Romillo and Upton, G.R. No. L-68470, 08 October 1985)