Short answer. No. Article 17 states plainly that prohibitive Philippine laws on public order, public policy, and good customs cannot be rendered ineffective by laws or judgments from a foreign country, or by determinations or conventions agreed upon there — a foreign contract or judgment cannot be used to sidestep them.
What the law says
Prohibitive laws concerning persons, their acts or property, and those which have for their object public order, public policy and good customs shall not be rendered ineffective by laws or judgments promulgated, or by determinations or conventions agreed upon in a foreign country.
Civil Code, Article 17 — Forms of Acts; Lex Loci Celebrationis. Read the full provision →
Public-order laws survive foreign laws and judgments
Article 17's closing sentence states the rule your question is asking about directly: prohibitive laws concerning persons, their acts or property, and those which have for their object public order, public policy and good customs shall not be rendered ineffective by laws or judgments promulgated, or by determinations or conventions agreed upon in a foreign country. A foreign contract, a foreign court's judgment, or an agreement reached abroad cannot strip a Philippine prohibitive law of its force here.
This is different from the rule on how a document is formally executed
Article 17 opens with a separate rule about form: the forms and solemnities of contracts, wills, and other public instruments shall be governed by the laws of the country in which they are executed. That principle lets the formalities of signing, witnessing, and notarizing follow local practice abroad. It is a narrower rule about form and formality — it does not extend to letting a foreign arrangement override a Philippine law meant to protect public order.
Acts done before Philippine officials abroad follow Philippine formalities
Article 17 carves out one further situation: when the acts referred to are executed before the diplomatic or consular officials of the Republic of the Philippines in a foreign country, the solemnities established by Philippine laws shall be observed in their execution. Even while physically overseas, an act performed before a Philippine consular or diplomatic officer follows Philippine formal requirements rather than the local country's.
What this means in practice
Put together, Article 17 draws a line between form and substance. The country where a contract or document was executed may generally govern its formalities. But where a Philippine law is prohibitive and exists to protect public order, public policy, or good customs, no foreign law, foreign judgment, or agreement made abroad can render that Philippine law ineffective — that substantive protection is what the closing sentence of Article 17 exists to guarantee.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Gianni De Munari vs. Thelma Gagui Asprec Also Known As Thelma De Munari, Thelma Picotto And Thelma Centeno And The Civil Registrar General, G.R. No. 262831, April 7, 2025 — read the decision on LawPhil →
- Maria Josephine Praxedes Octaviano vs. Karl Heinz Ruthe and Lisa Grace S. Bernales, Civil Registrar General, G.R. No. 218008, June 26, 2023 — read the decision on LawPhil →
- Jerzon Manpower and Trading, Inc., United Taiwan Corp., and Clifford Uy Tauzon vs. Emmanuel, G.R. No. 230211, October 6, 2021 — read the decision on LawPhil →
- Luzviminda Dela Cruz Morisono vs. Ryoji Morisono and Local Civil Registrar Of Quezon City, G.R. No. 226013, July 2, 2018 — read the decision on LawPhil →