Short answer. Yes, but it must first pass through a Philippine court. Rule 39, Section 48 gives a foreign judgment effect here — conclusive upon title over a specific thing, presumptive evidence of a right against a person — yet allows it to be repelled by evidence of want of jurisdiction or notice, collusion, fraud, or clear mistake.
What the law says
In case of a judgment or final order against a person, the judgment or final order is presumptive evidence of a right as between the parties and their successors in interest by a subsequent title.
Rule 39, Section 48 — Effect of foreign judgments or final orders. Read the full provision →
What the law says
the judgment or final order may be repelled by evidence of a want of jurisdiction, want of notice to the party, collusion, fraud, or clear mistake of law or fact.
Rule 39, Section 48 — Effect of foreign judgments or final orders. Read the full provision →
Two kinds of foreign judgment, two effects
The section starts from a threshold: it applies to a judgment of a foreign tribunal having jurisdiction to render the judgment or final order. It then splits the field in two. A judgment upon a specific thing is conclusive upon the title to the thing — the stronger effect, settling ownership of the thing adjudicated. A judgment against a person — the typical money judgment — is presumptive evidence of a right as between the parties and their successors in interest by a subsequent title. Presumptive, not conclusive: it counts in the winner's favour, but it can be contested.
Recognition, not automatic execution
Notice the language the section uses: the foreign judgment is treated as evidence of a right. A sheriff will not levy on property in Manila on the strength of a foreign decree alone; the judgment's effect plays out before a Philippine court, where the winner invokes it and the loser has the opportunity to resist it. What the section does is heavily tilt that contest. The foreign judgment arrives carrying weight — the holder does not have to fight the original dispute all over again from the beginning, because the judgment itself is the evidence of the right it declares.
The five grounds of resistance
The losing party is not left to relitigate the merits at will. The section fixes the grounds: the judgment or final order may be repelled by evidence of a want of jurisdiction, want of notice to the party, collusion, fraud, or clear mistake of law or fact. The first two go to the integrity of the foreign proceeding — a court that had no authority, or a defendant who was never properly informed. Collusion and fraud go to whether the judgment was honestly obtained. The last, clear mistake of law or fact, requires exactly what it says — a clear one, not a mere disagreement with the outcome.
What each side should gather
The holder of a foreign judgment should secure the official record of it: the judgment itself, proof it is final where rendered, and the material showing the foreign court's jurisdiction and the service made on the defendant, since those are the first points of attack. The party resisting should work the same list from the other end — evidence of defective notice, of the tribunal's want of authority, or of fraud in how the judgment was procured. Which side prevails usually turns on this record of the foreign proceeding, so both sides should have counsel assess it before the fight begins.