PHILIPPINE courts adhere to the doctrine of processual presumption, which generally means that where a foreign law is not pleaded or not proved even if pleaded, the presumption is that it is the same as Philippine law (EDI-Staffbuilders International Inc. v NLRC, GR 145587, 2007).
To have evidentiary weight in a judicial proceeding, the foreign law should be alleged and proved like any other material fact (Simundac-Keppel v Keppel, GR 202039, 2019).
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