The Department of Foreign Affairs received Memorandum Circular No. 2007-008 issued by the National Statistics Office (NSO) which establishes guidelines on the annotation of civil registry documents. The Memorandum Circular states that a foreign judgment or order requires judicial recognition by a Philippine court to prove its validity since these are not self-executory in the Philippines. The circular cited the Supreme Court ruling in the case of RP vs. Orbecido III (G.R. 154380, dated 5 October 2005) which states that “before a foreign divorce decree can be recognized by our own courts, the party pleading it must prove the divorce as a fact and demonstrate its conformity to the foreign law allowing it”.