What the koseki is
Japan does not issue PSA-style individual civil registry certificates. Civil status lives in the koseki, the family register kept at the city or ward office: marriages, divorces, births, and deaths are recorded as entries in the family's register. When one of those events has to be proven, the office issues certified paper drawn from the register — most commonly the Certificate of All Matters, a certified transcript of the register's entries, or, for a divorce, the Divorce Report filed and recorded at the city hall. For a Filipino seeking recognition of a Japanese divorce, these register documents often are the evidence, because a divorce by agreement produces no court judgment at all.
Moraña: the Divorce Report stood in for the divorce decree
In Moraña v. Republic (G.R. No. 227605, December 5, 2019), the lower courts dismissed the petition because no divorce decree had been presented. The Supreme Court reversed:
Records show that the Divorce Report is what the Government of Japan issued to petitioner and her husband when they applied for divorce. There was no "divorce judgment" to speak of because the divorce proceeding was not coursed through Japanese courts but through the Office of the Mayor of Fukuyama City in Hiroshima Prefecture, Japan. In any event, since the Divorce Report was issued by the Office of the Mayor of Fukuyama City, the same is deemed an act of an official body in Japan. By whatever name it is called, the Divorce Report is clearly the equivalent of the "Divorce Decree" in Japan, hence, the best evidence of the fact of divorce obtained by petitioner and her former husband.
The Court added that the fact of divorce was also supported by the Certificate of All Matters issued to the husband, showing the date of the divorce, the wife's name, and her nationality, and that the Divorce Report, Certificate of All Matters, and Divorce Certificate — all authenticated by the Japanese Embassy — were admissible as official records. The case still went back to the trial court, but only because Japanese law had been shown through website printouts; the koseki paperwork itself had done its job.
Ng: the Family Registry accepted, En Banc
The En Banc confirmed the same in Republic v. Ng (G.R. No. 249238, February 27, 2024), where the petitioner's proof of divorce included the register itself:
Here, Ng was able to sufficiently and satisfactorily prove the fact of divorce when she submitted into evidence the following documents: 1) an authenticated Divorce Certificate issued by the Embassy of Japan in the Philippines; 2) Certificate of Acceptance of Notification of Divorce; 3) Certification by the City Civil Registry Office of Manila acknowledging that a Divorce Certificate was filed and recorded in their office; and 4) an original copy of the Family Registry of Japan issued by the Mayor of Nakano-Ku, Tokyo, Japan with its English translation, evincing that the fact of divorce was duly recorded in the Civil Registry of Japan.
Note the pairing in item 4: the original register document issued by the mayor, and an English translation. Yet Ng too was remanded — not for any defect in the koseki proof, but because the Civil Code of Japan was shown only through an unauthenticated photocopy. The register proves the divorce; it never proves the law.
Getting koseki documents ready for court
- Obtain certified copies from the Japanese city or ward office that keeps the family register — for divorce cases, the Certificate of All Matters or the Divorce Report.
- Have them translated into English. The register documents accepted in Moraña and Ng carried English translations.
- Authenticate them. Japan issues apostilles through its Ministry of Foreign Affairs; embassy authentication, as in the decided cases, serves the same end. See apostille of Japanese documents and translation requirements.
- Pair them with the acceptance certificate. The strongest petitions prove the divorce from more than one direction; see the Certificate of Acceptance and the complete documents checklist.
Then deal with the second burden — properly proving Japanese divorce law — before filing, not after a remand. The full sequence is on the Japan divorce recognition guide and the firm page on recognition of foreign divorce.
Frequently asked questions
What is the Certificate of All Matters?
It is a certified transcript of the entries in a koseki, including the fact and date of a divorce. The Supreme Court accepted it, with an English translation and embassy authentication, as support for the fact of divorce.
Where do I get koseki records?
Certified copies are issued by the Japanese city or ward office that keeps the family register. For a recognition case, ask for the Certificate of All Matters or the record of the divorce.
Do koseki documents need to be translated?
Yes. The registers are written in Japanese, and the documents accepted by the Supreme Court carried English translations. They also need an apostille or embassy authentication.
Is the koseki extract enough to win recognition?
It can prove the fact of divorce, but recognition also requires proof of Japanese divorce law under the Rules of Court. Both must be presented, or the case risks remand.